In our last blog, our discussion revolved around the ambiguous nature of coders’ job descriptions. Today I want to discuss how we can restore some order and eliminate a lot of the ambiguity and uncertainty.
Today’s coders and coding teams must be flexible and ever so conscious in the difference in coding expectations of various organizations. But beyond that, how do teams of coders consistently adhere to the expectations? How does the consumer of the coded information know that their expectations have been met and how to use the information accordingly?
After mulling over these issues, talking to many colleagues and experts, and working with our internal team, some clear patterns have emerged:
- To what extent are coders expected to capture diagnosis codes (only diagnoses relating to HCCs and RxHCCs)? All diagnoses? Only the first DOS in a review period? All DOSs? Let’s call this the coding level.
- There are two schools of thought when it comes to HCC coding; the traditional view where all diagnoses have to have monitoring, evaluation, assessment and/ or treatment, and proper signatures (MEAT). The second group would include those who believe that a chronic condition does not require additional supporting documentation and that a lack of a proper signature should not deem a diagnosis non-submittal since CMS permits attestations, etc. etc. (what we called the gray areas in the last blog). Let’s call that ‘Tracking documentation deficiencies with Validation Reason Codes (VRCs).'
Armed with these concepts, we can now instruct coders very specifically and explicitly how to approach each medical record. At a minimum, you can specify the ‘Coding Level’ (we have defined three) telling coders exactly what they need to code and not code and have them capture at least one VRC for each diagnosis (we use up to 27). VRCs are the sharpest tool in the toolbox; they can cut the coding differences between teams, projects, even vendor teams like butter. If a diagnosis isn’t 100% RADV proof, a VRC would be assigned to denote the possible issues (documentation deficiencies). Issues can range from no provider signature, the diagnosis is in the assessment only, or there could be conflicting information within the date of service documentation.
Once the VRC codes are finalized, the results can then quickly and clearly be grouped into diagnoses/HCCs/RxHCCs that should/should not be submitted to CMS without any other review and which codes need further evaluation.
This will go a very long way to address ambiguities for coders and management and deliver the best possible results (including audit protection). Not bad, huh?
Certified coders’ job descriptions have once again been redefined due to CMS, OIG, their respective audits, and many other factors over time. We are now the gatekeeper of diagnoses, document translators, and finally coders. I am not sure how we managed to obtain all this power, and I am not even sure we should have it! Coders are trained to review documentation and abstract the correct diagnoses and procedures…code what the clinician documents.
Our new job descriptions now have us determining if sections of the chart have been copied and pasted from the previous visits (whatever happened to coding each DOS/encounter as a distinct document?), translating what the clinician documented (is the condition really a history or does the clinician mean the member has a history of….), and finally, we get to decide which codes are going to be submitted by determining if the diagnoses are “supported” by the documentation (what does “supported” really mean?).
The most frustrating aspect of this transformation is that no two coders are on the same page! Heck, no two national organizations are on the same page!! Wait, no two governmental organizations are on the same page!!!
There will always be “gray” areas in medical coding, but some of those “gray” areas could become black and white if representatives from the coding community had an opportunity to sit down with the governmental agencies monitoring health care coding (CMS and OIG) and have an open dialogue. Discussions around the use of “history of” and of chronic conditions documented in the PMH as well as standardization of coding rules for both outpatient and inpatient coding (Coding Clinics are customarily based on the inpatient setting and the majority of coding work is in the outpatient settings) would be a good place to start.
In my next blog entry, I will discuss best practices to address the challenges with these inherent ambiguities and to align coders and their work products in a meaningful and beneficial way.
With HEDIS® 2015 well behind us, now is the time to start planning for HEDIS® 2016. While the active medical record collection period is short, HEDIS® is a year-round activity and there are many opportunities to make next year results even better. It boils down to data gaps and identifying where those gaps exist. With that in mind, you can identify interventions for your health plans, providers, and members. Taking action to close these gaps can drastically improve your HEDIS® and STAR Ratings for the following year.
A few specific ways to improve HEDIS® 2016 scores:
- Assess and analyze what is driving gaps and close them: Such as out of network visits, providers not cooperating, and/or EMR integration not being utilized.
- Ratchet up provider engagement: Targeted reports that give providers up-to-date patient information can assist them in their outreach efforts to encourage members to receive timely care.
- Supplemental Data: Seek out other supplemental data sources that can help improve rates such as state registries for immunizations, health assessment data, and prior year hybrid exclusions (colorectal screening, breast cancer screening, etc.).
- Look for opportunities to reduce provider abrasion: Consider ways to help providers anticipate and schedule HEDIS® requests and explore technologies that reduce office disruption such as remotely accessing EMRs.
- Revaluate member engagement strategies: Consumers are demonstrating a willingness to adopt new care delivery models that are more convenient and lower cost. Payers need to experiment with technology enabled outreach programs that accommodate member’s increasingly mobile lifestyle.
The healthcare system is inherently challenging to navigate. By exercising strategies that encourage members to manage their health and facilitate greater provider collaboration, you lay the foundation for improving HEDIS® scores for 2016 and beyond.
Tags: STAR ratings, CMS 5 Star Rating, HEDIS audit, provider data, provider relations, HEDIS, NCQA HEDIS, provider abrasion, gap closure, EMR, HEDIS 2015, gaps, supplemental data, provider engagement, HEDIS 2016
Just because the HEDIS® reporting season has ended, doesn’t mean that there is not still valuable chart review to be done. Those charts that hold value for HEDIS® scores and Stars rating could be coming into your organization right now.
Risk Adjustment chart collection occurs virtually year-round and there is a very good chance that your plan is acquiring charts right now for that purpose. Although there are clearly limits to how you can use partial year chart data for HEDIS® reporting, mining these charts in the HEDIS® off-season can yield potential outreach opportunities and possible valid exclusions for low denominator, administrative-only HEDIS® measures.
HDVI’s STARs Improvement initiatives help plans leverage existing chart information from risk activities as well as gather additional charts as needed to impact several hybrid and administrative measures, including:
- Controlling High Blood Pressure
- Comprehensive Diabetes Care – BP
- Comprehensive Diabetes Care - Eye Exam
- Osteoporosis Management in Women who had a Fracture (OMW)
- Drug Therapy for Rheumatoid Arthritis (ART)
Although you cannot use the blood pressure values found in the chart to satisfy the actual reporting for HEDIS® 2016, review of these charts can help identify non-compliance mid-year and potentially focus outreach. In the cases of measures like OMW and ART, these generally have low denominators and fairly wide exclusion criteria. Locating only a few valid exclusions, that your auditor approves, can help a plan move the needle on these administrative-only measures.
With CMS’ recent announcement of the delayed implementation of HHS Risk Adjustment Data Validation (HRADV), a number of colleagues involved in risk adjustment for commercial exchange plans have been wondering if they should still be conducting mock RADV audits; or do something else; or do nothing for now. While I have never been an advocate for conducting ‘MOCK’ RADV audits in a manner that exposes a health plan to greater financial risk, I do strongly encourage everyone I talk with to conduct periodic RADV Preparedness ‘Fire Drills’ and Targeted Audits. Those plans that just got a reprieve from the HHS RADV are no exception.
So why should one bother conducting an internal audit of the accuracy and completeness of their Risk Adjustment data, when the regulators won’t be looking over their shoulder until 2018? To be ready when it counts. Clean up your data so that when the ‘one and only trial audit’ in 2016 occurs against your 2015 data, your plan doesn’t find itself trying to catchup with the competition. With only 20-30% of a commercially risk adjusted population having an HCC relevant diagnosis, just one missed code could mean the difference between a plan receiving a payment, or having to pay a competitor.
What are some of the things plans should be doing now? If you haven’t already engaged an IVA firm, hire one. Not necessarily to duplicate the exact IVA (for a number of reasons), but a targeted audit. The second thing I encourage is putting together a work team charged with conducting targeted audits of their data to get a better understanding of where the holes are in both process and data. Fix them. And audit again. It is worth the effort and not just for peace of mind, but financially as well. 2016 is just around the corner.
I recently watched a documentary series called ‘The Men Who Built America’ on Netflix. One of these men, Andrew Carnegie, is usually known as a Pittsburgh steel magnate, one of the richest people in history, and his philanthropic legacy including Carnegie Hall. Less well known, perhaps, is the fact that he started out in the railroad business.
So what does any of this, you may ask, have to do with how we perform Medical Records Reviews today? Bear with me…
After learning the ins and outs of the railroad business for a number of years, Carnegie started his first company which built railroad bridges like the Eads Bridge over the Mississippi which was completed in 1874. That bridge, with its massive span, could only be realized through innovation, specifically the use of steel. Daring and new at the time, the use of steel soon changed transportation and construction forever.
While these bridges are beautiful and amazing feats of engineering, the usefulness and benefits ultimately drove their realization. Innovation by itself never stands the test of time. Among other things, these bridges made travel and transportation much more seamless. No more loading and unloading, use of ferry boats, long waits, unpredictable schedules, etc.
Looking at how our industry performs Medical Records Reviews, especially the retrieval steps, I couldn’t help but think of what transportation must have been like before those bridges. Multiple vendors involved (even if it doesn’t appear that way on the surface), the tasks and steps are disjointed, disconnected or both, ability to keep track of status and issues is manual and delayed, and handoffs to coding teams are often clunky and painful.
I’d like to suggest that our industry can now widely embrace the innovation enabled and realized through software to run MRR projects in a seamless and integrated fashion. The technology for the end-to-end workflow exists, is proven, our industry is aching for it, and the plans using it are seeing the obvious and a number of additional benefits. So it’s about time we use software to build these bridges supporting a seamless process to get our MRR trains running fast, reliable, and inexpensively while making the experience a much better one for all involved.
If you are reading this, chances are you agree with my previous blog’s premise that performing concurrent risk adjustment activities are increasingly important. Or perhaps you had already arrived at that conclusion previously.
Just wanting to do something is not enough, however. A concurrent review process is sufficiently different from a retrospective one to merit serious thought and planning. As we have been developing our platform and adapting our services, we have learned some valuable lessons. Here are some of the top obstacles and pitfalls to be considered when moving towards concurrent:
- Data Flow: Having the right data to start with is critical. Aside from good suspecting and provider data, plans should take a Verify-Delete-Add approach. This means good encounter data is needed and the MRR platform needs to be able to handle that data to be useful.
- Provider Abrasion: Providers are bombarded with increasing numbers of chart pull requests. Provider abrasion is ever increasing as all of your competitors get into or increase the scope of retrospective chart reviews, especially now that commercial exchange plans also risk adjust. With concurrent, the frequency of chart requests goes up. It is critical to have an approach that does not further tax the already thin patience of providers.
- Taking Action: Aside from getting a clear picture of revenue and other aspects derived from medical records, a key aspects of concurrent review is gap closure. Tight review cycles afford plans the time to perform meaningful campaigns to close identified gaps. Make sure you have a plan and the tools to act on the information to close as many gaps as possible.
- Cost: It stands to reason that more chart review cycles will cost proportionately more money. Money that may not be in the budget. What can you do? Tackle the two main cost factors in the MRR process: Retrieval and Coding. A lot of it can be done with technology, to the point that the providers are actually less bothered than before. And a new approach to coding based on the encounter, not the chart. The numbers are surprisingly different.
Whether you are using our platform, another vendor’s or your own workflow, these issues will be constants and deserve all our attention as we expect to adopt concurrent reviews more and more.
Tags: SaaS, medical record review, risk adjustment, MRRV, provider data, provider relations, revenue optimization, MRR, revenue management, big data, provider abrasion, workflow, Coding, Concurrent, verify, verify-delete, retrospective chart review, gap closure, encounter, delete, retrospective, data flow
Historically, retrospective chart reviews were most commonly deployed for influencing risk scores and improving revenue. This look-back into a member’s medical record has often been 12 to 18 months beyond the encounter date. The delay in correcting the submission of data to a plan’s regulators contributes to a wide variability in risk scores and ultimately in reimbursement.
Regardless of which concern one focuses on, the need to submit COMPLETE and ACCURATE data in a TIMELY fashion is the recurring theme. Plans are compelled to remedy data (and document) lags. The sensible solution, then, is to continuously review medical records as medical encounter data becomes available.
This process essentially boils down to continual reviews focusing on recent encounters as driven by the encounter data (which is about as ‘concurrent’ as it gets). The triggering event for a concurrent RA review is driven by a claim submitted from a provider so abstraction of the medical record can be timely. In turn, this enables a host of follow-on activities, member outreach, provider education, and, more accurate and complete submissions to regulators through further integration with the plans EDPS processes.
So concurrent RA reviews enable a plan to better balance the information requirements of the regulators and to establish greater controls on revenue generating activities and the many related activities.
Implementing a concurrent review process can be tricky and costly. Read about some key considerations in our next blog.
Tags: quality improvement, quality measures, medical record review, risk adjustment, provider data, healthcare data, healthcare data analytics, revenue optimization, medical record analysis, revenue management, Concurrent, reimbursment, encounter, EDPS
As another HEDIS season comes to an end, most of us are carrying reminders that no matter how you approach the business of chart retrieval and abstraction, it seems to remain hard work with numerous dependencies for most health plans.
It’s typically at this time of year that I’m reminded of the guidance from W. Edwards Deming (one of the heads on my personal Mt. Rushmore of Quality Management) concerning supplier relationships. Deming’s philosophy of Total Quality Management and continuous improvement had been aggressively adopted by my then employer and having the good fortune of working at an organization with close ties to Harvard University, I had the privilege of attending a lecture given by Deming in 1990. Even at 90 years old he maintained an authoritative presence and spoke with a conviction and the passion of a recent convert.
The key message I took away from that hour with Deming was how much quality depended on the quality of relationships both those internal to a company, embodied in his message of “driving out fear” within an organization, as well as outward facing, embodied in his message about the value of investing in long term relationships with suppliers or vendor partners, as I like to think of our organization. Vendor partners that understand the needs today, have a vision for the future, can execute and have the competence and passion to work with their plan partners year-round.
I believe those two notions are exceedingly important in developing strategies to continuously improve the quality and completeness of hybrid reporting for HEDIS. A “one and done” approach to working with Medical Record Review or NCQA Certified HEDIS Software vendor partners will rarely address the issues related to reporting the most accurate HEDIS rates.
As a standard practice at HDVI, we advocate for and build year-round relationships with our plan partners and recognize that HEDIS hybrid rates are improved more from the work done by the plan-vendor partner teams between June and January (often called the off-season) than what is done between January and June will go a long way toward improving rates across the board for hybrid measures while often saving a lot of stress, aggravation and even money.