Beginning January 1, the CPT coding format for office and other outpatient visits will apply to hospital inpatient and observation visits, consults, and services in the emergency department, nursing facility, home, and residence, according to Part B News.
As a result, history and physical examination will no longer contribute to the level for these visits. Instead, for most visits practices will select codes based on medical decision-making (MDM) or time. The only exception will be emergency department visits, which will be MDM-only because the codes do not have a time component.
Among the most radical changes, Part B News says the AMA plans to delete all observation care codes and merge observation services with initial and subsequent hospital care codes.
The guidelines also include a revised definition of "New and Established Patients" that includes this addition: "In the instance where a physician or other qualified health care professional is on call for or covering for another physician or qualified health care professional, the patient’s encounter will be classified as it would have been by the physician or qualified health care professional who is not available."
According to Part B News, you’ll also find a new definition of "Initial and Subsequent Services" for patients who have been admitted to hospital inpatient, observation, or nursing facilities. In effect, the initial care codes apply when the patient has received no face-to-face services "from the physician or other qualified health care professional or another physician or other qualified health care professional of the exact same specialty and subspecialty who belongs to the same group practice, during the inpatient, observation, or nursing facility admission and stay," the guidelines state.
The update includes revisions to the MDM chart. Under low complexity of problems addressed, "1 acute, uncomplicated illness or injury requiring hospital inpatient or observation level of care," will be added to the list. In addition, there are two revisions to the examples for high risk of morbidity. Parenteral controlled substances will be added to the list of examples and "Decision regarding hospitalization" will be revised to "Decision regarding hospitalization or escalation of hospital-level care."
HealthLeaders' regulatory round up series highlights five essential governing updates that cover every aspect of the revenue cycle that leaders need to know. Check back in each month for more regulatory updates.
The revenue cycle is complex, detailed, and always changing, so staying on top of regulatory updates and latest best practices requires revenue cycle leaders' constant attention in this ever-changing industry.
In this revenue cycle regulatory roundup, there were an ample number of updates published by CMS and the Office of Inspector General in June, including code updates and audits of Medicare Advantage organizations.
Here are the five updates you need to know.
There were thousands of reasons for your coding departments to be overwhelmed in June.
A total of 1,176 new diagnosis codes were finalized within the fiscal year (FY) 2023 ICD-10-CM code update. The CDC also posted the FY 2023 coding guidelines along with the code update.
In addition to the 1,176 new diagnosis codes, the update also includes 28 codes that had revisions to their descriptors, and 287 codes deemed invalid.
On top of this, the FY 2023 ICD-10-PCS procedure code set and the ICD-10-PCS Official Guidelines for Coding and Reporting were released by CMS. The procedure code update includes 331 new codes.
Both updated ICD-10-CM and ICD-10-PCS code sets are to be used for discharges occurring from October 1, 2022, through September 30, 2023.
The coding department is one of the most critical parts of the revenue cycle. Because coding occurs mid-cycle, it provides an opportunity to catch errors introduced earlier in the process, as well as preventing similar errors in the future.
Staying abreast of these regulatory coding updates is important for revenue cycle leaders as coding—and its completeness and accuracy—has a profound impact on an organization's bottom line.
Tighten up your revenue cycle to avoid major penalties as the Office of Inspector General (OIG) takes aim at Medicare Advantage organizations (MAO).
On June 3, the OIG published a reviewof whether select diagnosis codes that Peoples Health Network, a MAO, submitted to CMS for use in the risk adjustment program complied with federal requirements.
The OIG conducted the audit by selecting 242 enrollee-years with the high-risk diagnosis codes for which Peoples Health received higher payments for in 2015-2016. The OIG found that 144 of the 242 enrollee-years had diagnosis codes that were not supported in the medical records and resulted in $412,938 in overpayments.
The OIG estimated that Peoples Health received at least $3.3 million in overpayments for these high-risk diagnosis codes in 2015 and 2016.
The OIG recommended that Peoples Health refund the federal government for the estimated $3.3 million in net overpayments, identify similar instances of noncompliance that occurred outside the audit period and refund any resulting overpayments, and enhance its existing compliance procedures to identify areas where improvements can be made to ensure high-risk diagnosis codes comply with federal requirements.
Peoples Health did not concur with any recommendations and said the OIG used flawed audit and extrapolation methodologies, did not evaluate the overall enrollee-year payments or risk scores, and failed to follow CMS' risk adjustment audit rules. The OIG says it stands by its original findings.
The Spring 2022 Semiannual Report to Congress was sent out by the OIG.
Some of the findings in the report include COVID-19 tests driving an increase in total Part B spending on lab tests, state performance in oversight of nursing homes, a study of Medicare beneficiaries utilizing telehealth services, and more. The OIG published a press release on the same date to accompany the report.
Medicare and beneficiaries paid substantially more to provider-based facilities in eight states than they paid to freestanding facilities in the same states for the same services.
On June 13, the OIG published a report of how much Medicare paid for certain services performed at provider-based facilities in 2010-2017 compared to what Medicare and beneficiaries would have paid for the same type of services performed at freestanding facilities during that same time period.
The OIG focused this review in eight states. It found that Medicare paid $3.1 billion and beneficiaries paid $794 million for E/M services at provider-based facilities when the same type of services at a freestanding facility would have cost $1.8 billion for Medicare and $460 million for beneficiaries during this time period.
In addition to the significant payment differential, beneficiaries would have only had to make one coinsurance payment if the services were performed at a freestanding facility rather than two that they had to make for the services at the provider-based facility. Cost-sharing generally would have been lower because it would have only been based on the freestanding facility rate.
The OIG noted that while CMS has taken some steps to equalize payments, those changes would not have completely leveled costs during the audit period. The OIG recommends CMS pursue legislative or regulatory changes to lower costs both for Medicare and for beneficiaries by equalizing payments as appropriate between provider-based and freestanding facilities for E/M services. CMS did not agree or disagree with the recommendations but noted that any changes now may require legislative action.
Inaccuracies in Medicare's race and ethnicity data hinder the ability to assess health disparities.
On June 15, the OIG published a review of the accuracy of Medicare's enrollment data on race and ethnicity. The OIG said this data, which currently only comes from the enrollment database, is key to ensuring that Medicare is able to assess health disparities appropriately.
The OIG found that the data is less accurate for some groups–particularly beneficiaries identified as American Indian/Alaska Native, Asian/Pacific Islander, or Hispanic beneficiaries. It noted that there are limited race and ethnicity categories and missing information, and while there are algorithms meant to improve the existing data, that falls short of self-reported data.
The OIG also said Medicare's enrollment data on race and ethnicity are inconsistent with federal data collection standards.
The OIG recommends CMS develop its own source of race and ethnicity data, use self-reported race and ethnicity information to improve data for current beneficiaries, develop a process to ensure that the data is as standardized as possible, and educate beneficiaries about CMS' efforts to improve race and ethnicity information. CMS did not explicitly concur with the first recommendation but concurred with the other three recommendations.
Special addition this month:The 2023 end-stage renal disease prospective payment system proposed rule is here.
Proposals include a change to the methodology for calculating outlier threshold for adult patients, rebasing and revising of the end-stage renal disease bundled market basket, and a permanent 5% cap on decreases in the end-stage renal disease prospective payment system wage index beginning in 2023.
CMS also proposed changing the definition of “oral-only drug” to include wording stating that it’s a drug or biological product with no injectable functional equivalent or other form of administration, and it proposed clarifying the descriptions of the end-stage renal disease prospective payment system functional categories to help ensure CMS supports innovation of completely new drugs and not variations of existing drugs.
CMS estimates payment updates in the rule will increase end-stage renal disease payments for freestanding clinics by 3.1% and increase payments for hospitals by 3.7%. The proposed CY 2023 end-stage renal disease prospective payment system base rate is $264.09. CMS published a fact sheet on the proposed rule on the same date. Comments are due by August 22.
Revenue cycle automation takes time, and as those at the University of Utah Health point out, you need to walk before you can run.
While time is always of the essence in the revenue cycle, implementing wider-scale change, like new processes and software, is better taken at a methodical pace.
Revenue cycle leaders at the University of Utah Health (U of U Health) successfully established an automated and streamlined audit process that identifies potential errors at the point of coding. When doing so, U of U Health was careful not to do too much too soon as it was imperative the workflow was right before getting too far.
Nancy Treacy, MPH, RHIA, CDIP, CCS, who helps oversee data integrity at U of U Health says that at least once in the process, it held off on implementing the next stage until issues were resolved and teams were truly ready to move on.
A timeline should be realistic and have a level of flexibility to it and taking time to slowly build on a new program has its perks that go beyond the organization.
The ultimate reason for automating and streamlining an audit process goes far beyond making the jobs of those in the revenue cycle easier, says Treacy.
"I believe coders and auditors are patient advocates. Patients are tasked with so much responsibility beyond focusing on getting well, and we help make sure they have a quality experience all the way to the end. With the proper tools and processes, we can ensure they get sent only one claim, helping to reduce confusion about what they can expect to pay. That's something we take seriously and are proud of," says Treacy.
Read more about U of U Health’s journey automating their audit process here.
New research estimates that a single primary care physician could add $124,435 in preventative services to their practice's annual revenue if coding and billing practices were rectified.
Physicians left a large amount of money on the table for services that were provided but not coded and billed, according to a recent study published in the Annals of Internal Medicine.
Researchers from Brigham and Women's Hospital and Harvard Medical School used national survey data to conclude that a single primary care physician (PCP) could add $124,435 in prevention services and $86,082 in coordination services to their annual revenue if coding and billing practices were resolved. They also estimated that each PCP provided preventive services worth up to $40,187 in additional revenue.
The authors analyzed 34 distinct prevention and coordination codes, representing 13 distinct categories of services for Medicare patients. They found that although services were provided to up to 60.6 percent of eligible patients, billing codes were only used at a median 2.3 percent.
According to the authors, the results suggest that having to navigate the eligibility, documentation, time, and component requirements of numerous separate codes may be too high of a hurdle to warrant the effort from PCPs to use prevention and coordination codes.
The physician fee schedule plays a dominant role in how primary care and other physicians are paid. However, core features of primary care—first-contact care that is continuous, comprehensive, and coordinated—are poorly matched with visit-based payments.
CMS has made efforts to address this issue by adding billing codes for these aspects of primary care including preventive services and for coordination services, but many of these codes have been characterized by low rates of adoption, suggesting that the codes are not being adequately used, the authors said.
Revenue cycle leaders share their experiences with measuring staff productivity in this new, remote workforce environment.
Like most of healthcare, the revenue cycle workforce has changed dramatically within the last several years. An entire office floor that previously housed a revenue cycle department is now silent and desolate as most staff have been working remotely for years at this point.
While working remotely has been a success for most organizations and is now a permanent work model, measuring productivity has moved to the forefront of concerns since staff are no longer under physical, constant supervision.
During the recent revenue cycle Healthcare Workforce of the Future virtual roundtable, executives got together to discuss how productivity has changed in recent years and share best practices for measuring productivity in order to get the most out of their fully remote or hybrid staff.
Marvin Mickelson, system director of PFS-shared revenue cycle at University of Kansas Health System, said that the productivity of his customer service team went through the roof when they were sent home at the start of the pandemic. In the office, the team couldn't meet their call documentation goal, which was three minutes.
"We have a goal of three minutes per call, and our customer service team was hitting four and five minutes a call while still in the office," Mickelson said. "Once they became remote, the team has been below three minutes a call for the past 22 months straight."
However, other departments didn't see the same boost in productivity, Mickelson said.
"Productivity per department is a mixed bag for us too," said Derek Dudley, assistant vice president of revenue cycle operations for Wellstar Health System.
"When we first sent staff home, like Marvin, we saw an immediate boost in productivity", Dudley said. "There was less distraction. Now though, I think distractions have started to creep back in and now we're dealing with the same productivity levels and potential challenges that we did pre-COVID-19."
Remeasuring productivity measures
These ebbs and flows of productivity since the beginning of the pandemic have made it essential for leaders to step up their procedures for measuring productivity across all departments, both in-house and remote.
Revenue cycle leaders now have to be more reliant on reports and work queue volumes. Instead of being able to manage staff in person by walking around, leaders now have to pull reports, activity logs, and manage work by volume.
"Our best gauge of productivity now is running daily productivity reports," says Dudley. "Productivity measures vary by department since the complexity of tasks can differ greatly, such as those writing complex appeals versus simple appeals."
"There's also a degree of variability in value-add tasks," he says. "When it comes to measuring our productivity, that's really what we're looking for: accounts that are being successfully resolved, reports showing system actions, and the staff's time in and out of the system. There is a myriad of ways that we can check from a distance to make sure staff is working effectively."
Mickelson agrees that his organization is similar. "We're also looking at touches on accounts. Staff have to work a certain number of accounts a day to meet the goal for productivity," he adds.
Quality assurance is also a really big part of measuring productivity, Mickelson says. "Staff can 'touch' an account for an hour if they want to, but if they don't do anything with it, it's not helpful. The team will have a lot of re-work to do."
Jason Driskell, vice president of revenue cycle at Lakeland Regional Health, says his organization can see how long staff are in a specific account and what tasks they performed while in that account, which has proved to be helpful when it comes to measuring productivity.
But, Driskell says, they can't see what revenue cycle staff should have done with an account through a report. "It would be more helpful to see exactly what staff should have done based on a work queue designation or denial code to resolve the account. We want to see if staff were able to address any follow-up issues that they needed to and compare that to what they actually did," he says.
The future for the revenue cycle workforce
Now that revenue cycle leaders are working to perfect new productivity measures for hybrid and remote staff, are these new standards here to stay, or will we need to dust off those dirty office cubes since staff will be back in the office full time? These leaders say remote work is the new norm and it's here to stay. At least for them.
"I’ve heard other leaders say that if staff can’t meet their productivity while working from home, we will just bring them back in the office," Driskell says. "I've actually had a complete and opposite approach to that."
"If their job is now at home, bringing them back to the office is no longer an option,” he says. "So, if staff can't manage our new productivity measures, then they have to be placed on a performance improvement plan. At that point, staff have to decide to work faster and more accurately. There isn't an option for coming back in the office to help with productivity because we don't have anywhere to put them at this point—we've eliminated those departments' on-site work areas."
Dudley agrees. "That's the same mentality we have in our organization, " he says. "We have had that transformative shift to remote work, and we aren't looking to bring staff back to an office. And plus, we are downsizing our offices, so we will not have the same level of space anymore."
The option of bringing staff back into the office to encourage productivity is officially designed out.
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A flurry of stakeholder complaints around the "convener" requirement for good faith estimates (GFE) has put pressure on CMS to take action.
Several major health care industry groups have issued statements in recent days calling for CMS to make changes related to its convener requirement, which asks providers to create charge estimates for some patients that cover not only their own services but those of downstream providers, according to Part B News.
For example, the American Hospital Association (AHA) executive vice president Stacey Hughes asked CMS to extend its "enforcement discretion" on the convener requirement beyond next January 1.
"Due to the lack of currently available automated solutions, this process would require a significant manual effort by providers, which would undoubtedly result in the convening provider being unable to meet the short statutory timeframes for delivering good faith estimates to the patients and could also lead to inadvertent errors," Hughes wrote.
The American Medical Group Association (AMGA) also sent an open letter to CMS saying GFE requirements have resulted in significant challenges for providers to effectively schedule, coordinate, and deliver care.
AMGA members report completing more than 45,000 GFEs in a month and expect that number will increase, according to the association.
"The current GFE requirements impose additional stress to an already strained healthcare workforce," said AMGA president and CEO Jerry Penso. "CMS should reform the process so that the estimates provide the information patients need without creating new administrative obstacles for providers to overcome."
It’s unclear how many organizations have faced a significant impact from the convener requirement, but Darryl Drevna, AMGA’s senior director of regulatory affairs, says some AMGA members who are part of health systems have been hit hard. Some members have told Drevna their systems have generated 45,000 to 50,000 GFEs since the policy took effect January 1.
When it comes to the "convener" requirement, which is all tied to the No Surprises Act, experts predict CMS will bend on the requirement but is unlikely to remove it entirely, according to Part B News.
Experts and health care personnel seem to agree the convener job poses difficulties.
According to a survey from the Workgroup for Electronic Data Interchange (WEDI), formal advisors to HHS on health IT, 86% of respondents say it would be very difficult or difficult for providers and facilities to determine who should be the convening provider or facility.
Some 83% of respondents supported delaying the requirement "until there is standardized data exchange process in place to communicate information between convening providers and co-providers/co-facilities."
Paul Johnson, the former Phoenix mayor who runs the care coordination company Redirect Health in Scottsdale, Arizona, told Part B News that his company also operates a clinic that has to follow policies that have stemmed from the No Surprises Act, and "from the clinic side these rules are really hard and we’re struggling to implement them."
However, Johnson also acknowledges that "from our customer's standpoint, balance billing and disclosure are high priority issues" and believes the convener requirement can be doable if all parties are cooperating.
As a care coordinator he routinely works with hospitals on billing for multi-provider service costs and finds that “when we work with hospitals around the country, we find a lot of them are very cooperative about helping us get a price and editing downstream costs,” Johnson says.
"Granted, a lot of others try to play games—they give us a price and send a balance bill to our customer." Johnson thinks for some hospitals this is still "a standard course of business... But [the No Surprises Act] is helping address that system issue."
Other experts point to additional issues that have to be squared away. "Groups within the provider community have been communicating both formally and informally with CMS about these requirements," David McLean, partner with Hall Booth Smith PC in Atlanta told Part B News.
"For example, take mental health providers. It’s very difficult to put together a GFE for their services because you’re looking at an open-ended term of illness and you can’t really create an upfront estimate," McLean said.
Drevna says the technical issue is a major part of the convener problem.
"There's no way to automate this process," he says. "Our EHRs don’t have the capability to transmit this sort of information or even communicate provider-to-provider when systems aren’t set up to share billing details provider-to-provider. They’re designed to work with payers."
Read more about this analysis and if experts see CMS relenting on this requirement on our sister publication Part B News.
More than half of hospitals evaluated in a recent JAMA study did not adhere to price transparency requirements, as researchers call for more scrutiny to ensure compliance.
The No Surprises Act, which became effective January 1, requires hospitals to post the prices for their most common procedures as well as a patient-friendly tool to help shop for 300 common services.
According to a recent study published by JAMA, out of the 5,239 hospital websites evaluated, roughly 51% of hospitals did not adhere to either price transparency requirement.
Almost 14% of hospitals studied had a machine-readable file but no shoppable display while 30% of hospitals had a shoppable display but not a machine-readable file, according to the study. It also found less than 6% of hospitals were compliant with both components of the mandate.
Researchers also found that hospitals located in moderately concentrated or highly concentrated healthcare markets were significantly less likely to be transparent with their prices. Concluding their findings, the researchers noted that greater scrutiny of organizations within these areas may be needed to ensure adherence to price transparency.
Other hospital characteristics such as total gross revenue, size, emergency service capabilities and ownership type were not associated with a facility's adherence to the mandate, they wrote.
The team acknowledged that their count of adherent hospitals could be an underestimate as some may have updated their websites within the study's three-month data collection window.
This study doesn't come as much of a surprise as earlier research shows similar results in the adherence to price transparency.
For example, a study published earlier this year by PatientRightsAdvocate.org showed that most organizations were not fully complying with the hospital price transparency rule.
The report assessed the compliance with the law by reviewing 1,000 U.S. hospitals out of the over 6,000 accredited hospitals in the country.
Of the 1,000 total hospitals reviewed in the study, only 14.3% were fully complying with the rule. The study also found that only 37.9% of the hospitals posted a sufficient amount of negotiated rates, but over half were not compliant in other criteria of the rule, such as rates by each insurer and named plan.
Some of the largest hospital systems in the country fell short in this study.
The Center for Disease Control and Prevention (CDC) released 1,176 new ICD-10-CM diagnosis codes for implementation on October 1.
A total of 1,176 new diagnosis codes were recently finalized within the fiscal year (FY) 2023 ICD-10-CM code update. The CDC also posted the FY 2023 coding guidelines along with the code update which will take effect October 1.
In addition to the 1,176 new codes, the update also includes 28 codes that had revisions to their descriptors, and 287 codes deemed invalid.
One example of a code description revision is in the diagnosis code for dementia in other diseases classified elsewhere without behavioral disturbance. The diagnosis code description for this diagnosis will be revised to “dementia in other diseases classified elsewhere, unspecified severity, without behavioral disturbance, psychotic disturbance, mood disturbance, and anxiety.”
As for the updated coding guidelines, a new guideline was added for the assignment of dementia which states that selection of the appropriate severity level (unspecified, mild, moderate, or severe) “requires the provider’s clinical judgment and codes should be assigned only on the basis of provider documentation unless otherwise instructed by the classification. If the documentation does not provide information about the severity of the dementia, assign the appropriate code for unspecified severity.”
The coding department is one of the most critical parts of the revenue cycle. Because coding occurs mid-cycle, it provides an opportunity to catch errors introduced earlier in the process, as well as preventing similar errors in the future.
Staying abreast of these regulatory coding updates is important for revenue cycle leaders as coding—and its completeness and accuracy—has a profound impact on an organization's bottom line.
Leaders at Intermountain Healthcare discuss their journey merging physician and CDI teams and implementing the use of AI to streamline its middle revenue cycle.
Strong CDI and physician collaboration directly contributes to the overall health of an organization's revenue cycle. With the growth of automation, data availability, and tracking, it is increasingly important for the middle revenue cycle to become a priority for healthcare organizations.
That's why Kearstin Jorgenson, operations director of physician advisor services, and Dr. Kory Anderson, medical director of physician advisor services, CDI, and quality, at Intermountain Healthcare worked to streamline their middle revenue cycle by bringing their physician and CDI teams together and implementing AI.
For Intermountain Healthcare, revenue integrity and revenue cycle optimization are the ultimate goals and building a united team within the middle revenue cycle focused on patient experience and safety produced high-quality results that aligned with high-quality care.
Finding and addressing the gaps
According to Jorgenson and Dr. Anderson, CDI and physician communication was a large gap in their revenue cycle. They would often reach out to the physician advisor department to ask for help to reach physicians, message items appropriately, and talk with them peer-to-peer.
Intermountain Healthcare was also dealing with archaic, manual processes and a lack of buy-in. This made it difficult to ensure the true clinical picture of the patient was captured and done in a way that allowed for accurate reporting on measures like case mix index, patient safety indicators, and risk of mortality scores.
This is when Jorgenson and Dr. Anderson knew they needed a partnership.
Individually the departments were strong, but they needed to work together to really improve their revenue cycle. At Intermountain Healthcare, CDI teams are the experts in documentation, opportunities, and trends, whereas the physicians have expertise in effectively communicating peer-to-peer.
When the CDI team began talks with hospital leadership about how best to bring the two areas of expertise together, it became apparent that having a physician leader in the CDI team would be beneficial.
The physician advisor department already had champions and educators, so it made sense to position them to be the frontline advocates with the CDI nurses on CDI work.
Meanwhile, Jorgenson and Dr. Anderson said there was an executive leadership change, and multiple departments (including the CDI and physician advocacy teams) came together under one umbrella: the office of patient experience.
Through all of this, the two teams were able to align their work in more meaningful ways. After transformational change and the new operational footprint was in place, Intermountain Healthcare focused on three areas critical to the success of this new collaboration:
Champions and advocates: Responsible for promoting the importance of the program, hosting regular meetings, and advocating for engagement in CDI workflows
Strategy: The Intermountain Healthcare team's strategy is built on three pillars
Their approach to engaging providers
The design of their CDI integration within the provider workflow
Their commitment to always bridging CDI and physician work to the patient
Data transparency: Focused on establishing key performance indicators with medical leaders, overseeing the dissemination of reports, and highlighting metric success to senior leaders
To help streamline even more, Intermountain Healthcare also turned to computer-assisted physician documentation powered by 3M AI, which provides best practice nudges to physicians during documentation, applies clinical reasoning across the patient encounter, and helps physicians get things right the first time, avoiding rework and associated administrative burden by the CDI team.
The benefits of added automation and of bringing the two teams together underneath the office of patient experience were vast, Jorgenson and Dr. Anderson said, as it puts the big picture emphasis on improving the patient experience and quality of care as opposed to solely looking through a financial lens.
With the two teams working together, it unites all the functions that contribute to the capture, management, and collection of patient service revenue.
Intermountain Healthcare says it is now able to effectively collaborate, which contributes to better coding and documentation capture, thus reducing the risk of noncompliance, optimizes payment, and minimizes the expense that comes with fixing problems later on.
"The loudest message for us is the patient," Jorgenson said. "We want to make sure we are doing the right thing for them, ensuring they receive safe, quality care and making sure we provide that care consistently."
Challenges and solutions
There were obstacles to undergoing such a large endeavor, Jorgenson and Dr. Anderson said. Getting engagement from physicians was one of the biggest challenges for the team—but there were solutions.
Once the two teams aligned, it was still tough to engage physicians, Dr. Anderson said. What made the difference was getting third-party benchmarking data on quality. Then the Intermountain Healthcare team wasn’t solely comparing themselves against other facilities or systems in the same area, but rather facilities and systems across the country.
"Seeing the data was eye-opening to our system leaders. Some of the data was very good, and other data was not so good. It led to the fact that we need to do well because this is what patients and other folks see about us as an organization and can use it to decide where they may or may not get their care," said Dr. Anderson.
Another challenge was that before the teams came together, they were dealing with manual workflows and processes that couldn’t support Intermountain Healthcare’s focus on quality and financial measures. While physicians and CDI teams are both invested in complete, accurate patient records, their workflows were often misaligned.
To make improvements and increase optimization, Intermountain Healthcare turned to AI.
When doing so, it was critical to intersect the new system with the physicians’ workflow in the EHR. The goal was to use AI to automatically nudge physicians about common document deficiencies up front. A change that would reduce rework and free the CDI team to focus on more complex quality reviews.
Following this change the results included:
The nudges proactively support physicians in addressing common documentation gaps before the note is saved
Physicians can rapidly address the nudges and gaps in real-time instead of having to dig for queries later
The AI generates a nudge when appropriate by continually applying clinical reasoning across the patient encounter
It brought together traditionally siloed physician and CDI workflows, enabling both teams to take advantage of the same clinical understanding
Intermountain Healthcare also redesigned the workflow for the new team through account prioritization and relying on AI to generate prioritized worklists focused on cases with the most opportunity for improvement. Since this change, quality indicators and second-level mortality reviews have become part of the standard workflow.
Uniting individual facilities within the healthcare system was also a challenge for the organization. Large healthcare systems may be united by a vision and a direction, but each facility has its own nuances and differences, and they aren’t all staffed the same.
Intermountain Healthcare found success by partnering with facilities on an individual basis to understand how they are best suited to own and drive the work and then tailor the approach from there.
Another challenge was hesitancy, said Jorgenson. Both the CDI and the physician advocacy teams have a lot of skilled, experienced staff, but when Intermountain Healthcare first aligned the two, Dr. Anderson and Jorgenson noticed that seasoned professionals were hesitant to admit when they didn’t know something. They didn't want to be seen as someone who didn’t have a depth of understanding.
They focused on that dynamic and worked to change it. When someone did ask a question or admitted that they didn’t know something, it was met with positive reinforcement.
"We’re stronger when we're able to rely on each other's expertise," Jorgenson said. "If you don't know something, that's fantastic. Bring it up."
Tips for other organizations
Center key performance indicators (KPI) on quality metrics
Dr. Anderson and Jorgenson have talked to numerous facilities around the country, and they see many aligning under a finance focus. Finance can be the loudest message sometimes, but what needs to resound is quality, they said.
Intermountain Healthcare focused on quality metrics that were directly impacted by clinical documentation, physician engagement, and education.
"We used to struggle to get an audience," Dr. Anderson said. "Now people are coming to us to talk about strategies and what they could do to improve those metrics."
Bring teams together in a way that still enables them to do their best work
For Intermountain Healthcare, the CDI nurses continue to focus on trends and identify what the team needs to learn. They collaborate with the physicians, and then the physicians go out and build relationships, look for common and shared understanding, and deliver educational presentations.
Bring education work in-house when possible
Intermountain Healthcare used to contract education out to vendors. Now the team does in-house training whenever possible.
Dr. Anderson and Jorgenson say they're getting better engagement with providers because educational sessions are happening between colleagues.
The person leading the session and those who attend see and work with each other in the hospital every day. This allows for more natural accountability and continuous improvements and adjustments because conversations can happen on the job and in the moment, they said.
Follow-through is also greater with in-house education. Intermountain Healthcare has set up quarterly meetings to connect on what’s going well, what isn’t going well, and how to close the gaps.
Seeing results
While it's still early in the initiative, Intermountain Healthcare has already achieved results from merging teams and implementing AI.
Intermountain Healthcare says CDI efficiency has increased similar to having hired 4.6 additional specialist RNs. The increase in efficiency has allowed the CDI team to focus on more complex quality and mortality reviews.
Intermountain Healthcare has also seen significant improvements in patient safety indicator trends and a decrease in patient safety indicators, a better case mix index, improved risk of mortality scores, and higher query response rates.
Substantial progress was also made in engaging physician groups, particularly hospitalists and intensivists, and physicians are now documenting some conditions on their own without being nudged, Dr. Anderson and Jorgenson said.
Intermountain Healthcare says all of this has helped them accurately represent the complex patients they take care of in a way they weren’t able to before.
"Moving from a financial focus to a quality focus gave us a platform for change," Jorgenson said.
What’s next
Intermountain Healthcare is working to finalize its computer-assisted physician documentation rollout to rural facilities within the system while also diversifying the provider nudges.
Quantification and optimization of evidence sheets, leveraging technology to better identify clinical cohorts for review, and continuing to think through more complex CDI opportunities are all part of Intermountain Healthcare’s future plans in optimizing its middle revenue cycle.
The procedure code update includes 331 new codes to be used for discharges occurring from October 1, 2022, through September 30, 2023.
The ICD-10-PCS update includes tabular updates for heart surgeries and digestive operations performed with laser interstitial thermal therapy. CMS also made updates to reporting procedures involving new technologies.
At the same time as the code update, CMS released the procedure coding guidelines, which include new guidelines for reporting procedures of certain extremities.
The coding department is one of the most critical parts of the revenue cycle. Because coding occurs mid-cycle, it provides an opportunity to catch errors introduced earlier in the process, as well as preventing similar errors in the future.
Staying abreast of these regulatory coding updates is important for revenue cycle leaders as coding—and its completeness and accuracy—has a profound impact on an organization's bottom line.
