Note from the Associate Editorial Director: Establish query policies prior to CDI program launch

by Melissa Varnavas

An ACDIS member recently recounted a disappointing story regarding her facility CDI program implementation. Essentially, the nurses performing concurrent queries disagreed with the coders at nearly every turn. I’m sure many of you can relate to this predicament. In the end, the facility brought its lawyer and compliance officer to the table. A good move which maybe might have saved some aggrevation if they’d been at the table from the beginning.

The coding rules and regulations are strict and too often seem to conflict with clinical common sense. RNs believe they’re perfectly entitled to ask a physican a basic question regarding patient information in the chart regardless of whether the question may be construed as “leading” by outside auditors.

So I thought it might be a good idea to post a short excerpt from the article Establish physician query protocols to resolve compliance risks in the July 2009 issue of the CDI Journal. In the article Andrei M. Costantino, MHA, CHC, CPC-H, CPC, director of organizational integrity at Trinity Health in Farmington Hill, MI, Robert S. Gold, MD, CEO of DCBA, Inc., in Atlanta, and Robert A. Wade, Esq., a healthcare attorney at Baker & Daniels, in South Bend, IN, offer tools to help keep CDI programs compliant with government rules and regulations.

Creating policies and procedures for your query processes is one way to help eliminate risk. Legal penalties for filing false claims due to leading physician queries won’t seem like a misdemeanor if the Office of Inspector General and the U.S. Department of Justice (DOJ) investigate. The CDI program could unduly influence physician documentation. Such influence could in turn cause compliance headaches or, worse, a False Claims Act lawsuit.

Creating policies and procedures for your query processes is one way to help eliminate risk. It’s also the reason many experienced CDI administrators know their compliance officer and legal counsel, and it’s also why new program leaders should introduce themselves to the compliance department as soon as possible, says Costantino.

The CDI Journal is the quarterly publication of the Association of Clinical Documentation Improvement Specialists (ACDIS) and is free for its membership.

Editor's note: Varnavas is the associate editorial director of ACDIS. Contact her at mvarnavas@acdis.org.