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By Mike Evans, RHIA, CCS, vice president of coding and compliance at In Record Time, Inc.

Internal coding audits have always been important. However, as third-party auditors continue to scrutinize documentation and coding practices, it’s more important than ever to ensure that these audits occur regularly and that they’re effective. All too often, internal auditors overlook critical aspects of the audit, resulting in skewed data that may not paint a clear picture of trends and patterns. Even when conducted properly, audits may not yield results that are truly useful to the organization.

 Following are some of the most common mistakes that internal coding managers and/or HIM directors make when conducting internal coding audits.

 1. Audits are too narrow. Internal managers sometimes approach an audit with an agenda to increase CC or MCC capture. When organizations narrow their focus in this way, they may miss out on other problems within the documentation or coding. Instead, organizations should focus audits on documentation integrity—not simply identifying missing elements that would have increased reimbursement. Ideally, audits should ensure the following:

 ·         Multiple CC and MCC capture, when appropriate. Capturing only one single CC or MCC may not be sufficient in terms of ensuring a correct severity of illness (SOI) or risk of mortality (ROM). SOI and ROM both affect the observed vs. expected death rate—an important indicator of the quality of care provided.

·         Correct POA indicator assignment. This plays an important role in patient safety indicator (PSI) scores. An inflated POA indicator rate could inflate the PSI rate as well.

·         Compliant complication reporting. Physicians are hesitant to label complications as such; however, organizations need to encourage physicians to document complications when they occur. Reiterate to physicians that complications that occur intra-operatively are generally not the fault of the physician, but rather they’re due to a problem with the patient’s own health circumstances.

 2. Audits don’t look beyond the organization’s own walls. One of the biggest mistakes that organizations make is not looking at how their data compares with other facilities in the state, region, or nationwide. Knowing how your organization compares with its peers is important because patients have access to this data that is reported on an aggregate level to various state health agencies. Sites such as Physician Compare and Hospital Compare make it very easy for consumers to shop around for the best quality care. Organizations need to know how they stack up against other facilities so they can take steps to improve data quality and public perception.

 Knowing how the organization compares with others is also important in terms of gauging vulnerability for external audits. The Program for Evaluating Payment Patterns Electronic Report (PEPPER) is a helpful resource that provides hospital-specific data statistics for improper payment targets. Organizations can use PEPPER to compare their data other hospitals or facilities in the state, specific Medicare Administrative Contractor (MAC) jurisdiction and the nation.

3. Auditors don’t look for the story behind the numbers. Internal auditors may not look for the root cause of audit results. Instead, they must simply assume that the results are based on incorrect coding. However, the trigger may be something process-related and/or entirely unrelated to coding. For example, if the organization’s procedure is to require coders to code without the discharge summary, this might affect a coder’s ability to capture the principal diagnosis correctly. Consider a transient ischemic attack (TIA). When a physician documents both a TIA and a cardiovascular accident (CVA) throughout the record—but doesn’t rule out the CVA until the discharge summary—how can the coder truly know what proper principal diagnosis to report?

Another example relates to septicemia vs. urinary tract infection (UTI). Are coders required to query when the record is unclear? Are they given sufficient time to do so? If not, unclear documentation could lead to an unusually high rate of septicemia that could appear quite alarming during an audit.

Other root causes could relate to insufficient physician documentation, EHR glitches, etc.

 4. Auditors don’t use updated resources. It’s a full-time job to keep up with ever-changing audit targets and requirements. However, using outdated resources and references can provide skewed audit results. Be sure to use updated coding guidelines and updated insurer policies. The Recovery Auditor FY2013 Report to Congress and FY 2015 OIG Work Plan are also good references in terms of structuring an audit and keeping updated on the latest targets.

 5. No follow-up education is provided. After the conclusion of an internal audit, provide audit results to coders, physician advisors, and CDI specialists. Include a physician advisor when providing education to physicians, as they generally respond more positively when receiving information from a peer.

 6. Organizations don’t perform follow-up audits. Perform an audit six months after concluding the original audit. This ensures the efficacy of any steps taken to rectify problems identified during the first audit.

 How an external vendor can help

External coding vendors provide an unbiased look at an organization’s data. These auditors don’t have an agenda, and they also have no connection to the data. They often provide the impartial analysis that organizations need.

 In addition, external vendors can perform the type of in-depth data analysis necessary to compare an organization’s performance (i.e., its DRG and APC mix) with similar facilities on a city, state, regional, or national level. Many external auditors work with clients nationwide, meaning they bring a wealth of knowledge and experience to the table. Organizations benefit from this bird’s-eye view of what’s going on in the industry in terms of third-party auditor trends.

By Mike Evans, RHIA, CCS, vice president of coding and compliance at In Record Time, Inc.

Now that ICD-10 has been delayed until October 1, 2015, many organizations are left wondering how to make the most of this interim time. Our experience has been that as many as 50%-60% of hospitals slowed their ICD-10 efforts when the delay was announced. Although many organizations have chosen to put ICD-10 on a back burner for now, this isn’t necessarily the best solution, nor will it yield the most effective long-term results. Instead, HIM professionals—with the support of executive leadership—should devote as much time as possible to auditing, documentation improvement, and physician engagement.

 Consider the following strategies:

1.      Be transparent with physicians. Any major change can be scary and overwhelming, and the transition from ICD-9 to ICD-10 is no different. Even though they may not admit it, physicians could be among the most anxious about the new coding system because they know that their documentation will affect code assignment directly. Physicians may feel as though there simply aren’t enough minutes in the day to document some of the details required by ICD-10. To complicate matters, physicians face many other administrative challenges as well, such as Meaningful Use and quality reporting, both of which can affect their bottom line. Many of today’s physicians feel overburdened by a healthcare system in which third-party audits continue to mount, and additional regulatory requirements seem to grow annually.


The American Medical Association and various subspecialty organizations have voiced considerable opposition to ICD-10. Many physicians feel as though ICD-10 is being forced upon them rather than integrated into their daily workflow based upon their own input. This could be because many physicians weren’t involved in ICD-10 since the very beginning of its clinical modification for the United States. Although HIM professionals can’t rewrite history, they can talk openly with physicians, address their concerns, and most importantly, acknowledge their frustrations. Consider these tips:

·         Keep physicians in the loop. Send regular communications to medical staff about ICD-10 developments and news. Physicians will appreciate the outreach.

·         Focus on severity of illness (SOI). SOI has become incredibly important in terms of outcomes and data reporting. Every physician must understand how his or her documentation affects SOI scores because eventually, this information may affect one’s ability to participate with hospitals and insurers that will only want to contract with those who have the best quality outcomes. As Accountable Care Organizations continue to grow, only the best and brightest physicians will likely survive and thrive.

·         Listen. Simply listening to a physician voice his or her frustration about documentation requirements may go a long way in terms of changing his or her behavior. Let physicians know that the HIM department is available to answer questions and serve as a resource for physicians.


2.      Ensure time for dual coding. Although it may be difficult to justify dual coding indefinitely, coders need hands-on practice with ICD-10. This critical practice time coding records in both ICD-9 and ICD-10 allows coders to identify documentation gaps and educate physicians accordingly. Working with an outsource coding vendor can help create time for internal staff to dual code without interrupting cash flow. Start with high volume and/or high cost diagnoses and procedures to maximize efficiency.


3.      Identify a physician champion. HIM professionals know that it can be difficult at best to change physician behavior. If organizations haven’t already identified a physician champion, they should take the time provided by the delay to do so now. Consider these tips:

·         Choose an individual who is well-respected and an excellent communicator.

·         Look for someone who has excellent EHR skills and whose documentation can set an example for others.

·         If possible, identify one physician champion for medical cases and another for surgical cases. This avoids overburdening one individual, and it also helps send a message to the entire medical staff that the organization values their input enough to devote multiple resources to the effort.

4.      Work with your outsource vendor to identify additional strategies. Organizations that outsource all or a portion of their coding to a vendor should work closely with that vendor to identify opportunities for documentation improvement. A reputable vendor should perform ongoing quality reviews and audits and be willing to share that information with the organization.

ICD-10 delay causes challenges for HIM professionals:

Moving forward during uncertain times

 By Mike Evans, RHIA, CCS, vice president of coding and compliance at In Record Time, Inc.

When the ICD-10 delay was announced in April, most HIM professionals cringed at the thought of having to spend yet another year in limbo preparing for the transition. Working with an extended timeline has posed variety of challenges that physicians, legislators, and others in favor of a delay had not likely considered. Following are some of the most striking ones that affect HIM professionals directly.

Expensive coder refresher training. Many organizations had begun to provide coder training in anticipation of the original October 1, 2013 deadline and subsequent October 1, 2014 deadlines. Not only must these organizations now provide ongoing refresher training, but they’ll also need to consider careful strategies to retain coders in whom they’ve invested significant training dollars. Personnel changes complicate matters. As coders come and go (e.g., as coders find new jobs elsewhere, take time off, or retire), it becomes more difficult to maintain a secure set of knowledge.

Increased overall costs. In 2012, CMS estimated that a one-year delay could cost the industry as much as $6.6 billion. This statistic was reiterated in a letter from the Coalition for ICD-10—a constituency of organizations across the healthcare spectrum—to CMS dated April 11, 2014. According to a February 2012 Edifecs survey of industry reaction to the potential delay of ICD-10, 49% of respondents estimated that every year of delay would increase their required budget by 11%-25%. Thirty-seven percent estimated an increase of 26%-50%. Increased costs can largely be attributed to the need for ongoing training as well as outsource coding assistance so internal coders can gain hands-on experience with ICD-10. The longer the industry works with both ICD-9 and ICD-10, the greater the impact on overall productivity and cost.

The need to regain executive buy-in. HIM professionals may unfortunately bear the brunt of CFO frustration with ongoing ICD-10 costs. When the most recent delay was announced, many CFOs made the decision to drastically reduce ICD-10 budgets or even cut them entirely. Now, HIM professionals must restart facility-wide momentum even in the midst of ongoing skepticism. HIM professionals must re-engage executive leaders and medical staff in the ICD-10 effort. This will not be an easy task during a time when initiatives such as Meaningful Use, EHR implementation, hospital acquisitions and mergers, and a variety of other changes are vying for physician attention and hospital resources.

The need to re-engage physicians. It was difficult to engage physicians before the delay was announced. Now, it’s even more difficult to convince them that ICD-10 will, in fact, go live on October 1, 2015. Engaging physicians is an expensive and time-consuming effort that often requires the identification of physician champions, detailed documentation auditing, and personalized physician education sessions. Many physicians may be particularly resistant to learning the nuances of ICD-10 because they are unconvinced of its importance. This creates ongoing challenges for HIM professionals who must find creative ways to obtain physician buy-in.

Fear of the unknown. Experts agree that coder productivity could decline as much as 50% in ICD-10. The specific decrease will depend on a coder’s experience and education as well as system integration. Coders have been coding with this fear for several years. Some coders have even retired out of fear. Managing workers in an environment in which uncertainty and fear remain high has been—and will continue to be—challenging.

 As organizations continue to uncover challenges resulting from the ICD-10 delay, it’s important to consider these tips:

 ·         Provide ongoing refresher training for coders. This should include training in anatomy, physiology, pathophysiology, and ICD-10 guidelines. Allow coders to dual code regularly as well as attend state and local coding chapter meetings where they can receive cost-effective training. Also explore other free and low-cost training options.

·         Talk openly with coders so you can understand their short- and long-term employment plans.

·         Open the lines of communication between HIM and the C-suite. Set realistic expectations for budgeting that will allow for flexibility while also ensuring enough dollars for ongoing training.

·         Re-examine coder responsibilities. As the industry moves closer to ICD-10, coders must focus specifically on coding. If their duties also include abstracting or release of information, for example, consider reassigning those responsibilities to other staff members. This will help mitigate productivity loss and give coders more time to practice ICD-10.

·         Identify physician champions who can assist with physician re-engagement.

·         Consider outsourcing some or all of your coding. Maintaining an internal coding department may not be a cost effective solution at the present time.

Absolutely NOT!! First and foremost, no one has implied that all areas of training have to be extensive and expensive. What must be all-encompassing, however, is the evaluation of skill level in these areas. First, determine the level of standardized skill required (such as 90th - 95th percentile success) in a pre-designed set of assessments; this way, the coder would only need to remediate areas where his/her proficiency may be lacking. Those skills that the coder currently maintains at a high level would need no further repetition. One critical link is recognizing that the coders are adult learners and the material must be designed (either for skill evaluation or training) with adult needs in mind while recognizing that most coders work at minimum a 40 hours/week and have obligations outside work.

Our profession was very fortunate when a group of health information administrators and technicians were selected from inception in the design and development of ICD-10-CM and PCS. Their trials and tribulations along their journey paved the way for our successes. As a profession, we strive for data quality being job#1, and nationwide standardized diagnosis and procedure coding can only be accomplished if all coders have similar skill sets. When taking this into consideration, we must recognize that many of our current coders have been out of mainstream education for greater than 5-15 years and have focused their educational efforts around yearly continuing education units for an outdated ICD-9-CM classification system.

Take a look at each of the two new ICD-10 coding classification systems. Both are so advanced and so exact in their code design and definition that we will have more clarity to become more standardized. This, however, can only be accomplished by understanding the medical sciences surrounding each of the ICD-10 coding systems and being able to apply this knowledge into the correct coding structures and functions as defined by our medical documentation.

In the next blog, we will discuss coder training needs for the two coding and classification systems. Remember, we are not to far away for the ICD-10-CM and PCS go-live date of October 1, 2014.

What can In Record Time do for you now, individually or for your organization, to ease the stress associated with your ICD-10 preparation? We can provide you with an ICD-10 training solution and/or the remote coding support that you need during this time! Contact us today!

A needs assessment must be developed very early on in the process of developing the ICD-10 program.  Because so many players inside and outside of HIM/Coding will be affected by the need for these new codes, a department-wide and individually-specific needs assessment must be developed.  This assessment will give the individual an opportunity to perform a self-assessment of his current education and subsequent skills in anatomy, physiology, medical terminology, and coding along with specific needs for any ICD-10 data.  The departmental needs assessment will give the department director an opportunity to assess the needs of their department’s data needs prior to implementation.  Collection and correlation of data is key in determining how the hospital moves forward in their planning stage.

Contact us today to find out how In Record Time can assist your HIM Department with preparation for ICD-10 CM and PCS!

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