Tip: Take some time to update your CDI program with an eye toward compliance

When evaluating overall compliance within a CDI department, Lynne Spryszak, RN, CCDS, CPC-A, CDI education director for HCPro, Inc., in Danvers, MA, says that CDI department managers should:

• Try not to confine your reviews to a particular payer. Although everyone has to start small when initiating a CDI program, your position policy should state that your process is “across all payers” and then work toward that goal. You don’t want to create a perception that you are treating Medicare or Medicaid beneficiaries differently than other patients (doing so is a big “no-no” from the governments standpoint.)
• Query consistently, not just when it affects the DRG assignment. On review, it’s easy for someone to see when queries are only generated to “get more money.” If a query gets you less money (present on admission conditions, CC/MCCs), query anyway to ensure a complete medical health record. You want to establish a pattern of compliant practices. You want those outside auditors to work extremely hard to identify recoupment issues.
• Establish one query policy and procedure that covers everyone on the team.  Everyone should be querying using the same criteria, whether they’re nurses, coders, or physicians. Number one: It makes your practice consistent. Number two: It makes life easier for everyone.
• Establish internal auditing processes to analyze queries for compliance against your policy. And be sure to do these audits routinely. Keep records of such audits so that you can prove that everyone is consistently using the same process (just in case there’s trouble down the line). “My team had a very scientific audit process—I gave mine to Mary, for example, and Mary gave hers to Sue, Sue gave hers to me. We analyzed the format, wording, appropriateness of choices then perform random record reviews to validate the queries’ appropriateness,” Spryszak says. 
• Keep records of continuing coding and/or CDI education. It will show that your team is kept up-to-date with the latest information regarding compliant practices.