Guest Post: Three things to watch in the Federal Register to foresee CDI’s future
RHIA, CCS, CDIP,
CCDS, FAHIMA
By Susan Wallace, MEd, RHIA, CCS, CDIP, CCDS, FAHIMA
Believe it or not, the Federal Register is one of the best crystal balls to foresee the future of CDI. There are a few reasons for that:
1. CMS has promised to refine payment systems to take advantage of the increased specificity of ICD-10 since the early planning stages of the code set’s implementation. The fiscal year (FY) 2018 inpatient prospective payment system (IPPS) final rule makes good on that promise and we should expect changes to the CC/MCC list during the coming year.
“…we have plans to conduct a comprehensive review of the CC and MCC lists for FY 2019. Therefore, we will be evaluating all of the ICD-10-CM diagnosis codes for this effort.”
2. CMS makes “improvements” to quality and reimbursement systems based upon analysis of claims data. Hospitals should take every opportunity to seek optimal documentation to support ICD-10 specificity regardless of its current impact on quality measures or reimbursement. CMS really telegraphs their own crystal ball to let facilities know they have much more in mind. Consider this statement from the FY 2018 IPPS final rule (emphasis added):
“Looking ahead to the needs and uses of coded data as the data continue to evolve from the reporting, collection, processing, coverage, payment and analysis aspects, we believe the need to ensure the accuracy of the coded data becomes increasingly significant.”
3. CDI specialists have to look beyond 2019 when evaluating the need for comprehensive documentation to support quality initiatives. The FY 2018 IPPS final rule outlines claims-based quality measures all the way to 2023. What many do not realize is that the discharges being coded in 2018 affect quality metrics that will form the basis of quality-based payments well into 2023.
Editor’s note: Wallace is the vice president of inpatient services at Administrative Consultant Service, LLC, in Shawnee, Oklahoma. The opinions expressed do not necessarily reflect those of ACDIS or its advisory board. Contact Wallace at swallace@acsteam.net.