RAC- audit

I just received a letter from IFMC (Iowa Foundation audit for medicare). It was
forwarded to me by my director. In the letter it was addressed to the primary
physician in regards to her secondary diagnoses. This patient was admitted with
pneumonia. In her H&P, she indicated hx of CHF, and in her progress note, she
wrote "chronic systolic HF". She also documented "acute on chronic renal" in her
H&P as well. We, the CDSs did not have to ask her on type of CHF, she already
done that for us. However, she had an in complete dx: "acute on chronic renal".
Therefore, one of us asked her what she meant, and she wrote back "acute on
chronic renal failure".

Now, the IFMC indicated in the letter that pt was tx'd for her CHF nor for her
Acute Renal failure. Therefore, those two dxs should be taken out, leaving only
DRG 195. Further review on this record with my PA found this:

1. Patient did have hx fo CHF, and on her previous admission, physician did
document the same thing. Pt was on PO lasix at that time. On this admission, no
po lasix given. No IVF given.

2. Could PMD w/held po lasix this time d/t increased in creatinine level? She
did mention in her note that she would continue to monitor pt's renal status.

3. Our coders query physicians left and right whenever they see "CHF"
documented, therefore, our docs are all trained to document the specifics for
us. Isn't this a requirement from MDCR coding?

4. Clarifying the documentation in the chart is part of our job, right?

My PA (physician advisor) will be speaking to this primary physician, and
together, they will write a letter back to IFMC. We will see what happens.




Comments

  • edited May 2016
    I made a mistake here. Pt was NOT tx'd for her CHF or ARF.


  • Did the MD document in the chart why they withheld the lasix and did not administer IV fluids? We have not had RAC audits yet but we are audited by the stated Medicaid auditor and this has been an issue.
    If the patient has a diagnosis such as CHF but is not being treated during the admission the MD needs to document why they are withholding the medications. The same for the renal failure. We have been denied payment because the labs and treatment did not support the diagnosis. I do want to say that we do not review Medicaid charts at this time.



  • Hi Ellen!

    After doing several record audits for DRG validation with an eye toward RAC liability I would just say this:

    If you have any final DRG assignments with only one MCC combined with a relatively short length of stay, these records are sure to be targeted by the RAC. They will stick out like sore thumbs when your DRG data is crunched by an auditor, and will likely be targets in the future for complex reviews.

    It's too late to go back and do anything about the records going back to 10/1/07 (the look-back date) but it's not too late to institute pro-active processes now.

    One of the many issues under RAC scrutiny are high-weighted medical DRGs with short lengths of stay. Currently the contractors all seem to be saying that medical necessity reviews are excluded (whew!)but those are coming, too.

    I would encourage everyone to develop a "second set of eyes" review process for ALL DRG cases with only ONE MCC. This can be done concurrently by asking a CDS colleague to take a "peek" and see what he/she thinks: does the patient's condition, treatment plan and documentation clearly support the MCC? Then, after discharge, have your DRG analyst or coding manager do a second look before the bill is dropped.

    Considering CHF or some of the other DRGs - the reimbursement isn't much to begin with but the appeal process will cost a lot more than the extra time spent on this front-end process.
  • edited May 2016
    This is scary because we have had an outside consultant agency tell our CDI nurses and Coders that CHF is considered a "Chronic Condition" and should be looked upon like COPD, Diabetes, Parkinson's Disease and Hypertension.

    See Coding Clinic 2nd Q 1992, pg 16-17, " COPD is a chronic condition which would affect the patient for the rest of his life. Therefore, if there is documentation in the medical record to indicate that the patient has COPD, it should be coded. If the physician mentions the COPD only in the history section and then again on the attestation with no contradictory information, the condition should be coded. The same would be true for other chronic conditions such as diabetes mellitus, hypertension, and Parkinson's disease".


    Kim Carr, RHIT, CCS
    Core Measure and Clinical Documentation Improvement Manager
    Care Management
    Erlanger Medical Center
    975 East Third Street
    Chattanooga, TN 37403
    phone # 423-778-4225
    email-kimberly.carr@erlanger.org
    Life isn't about how to Survive the Storm, but how to Dance in the rain!!!!


  • edited May 2016
    Thanks for the advise. Our hospital did have a physician advisor in coding
    department to look at all DRGs with 1 MCC or 1 CC. He made sure those were
    supported by clinical record before bill is dropped. The process started last
    year, and lasted about 9 months. The PA found no "up coding". He stopped his
    auditing because he felt we were doing a good job.

    Unfortunately in the case I mentioned. This doctor does not have the best
    documentation especially when she is in a hurry. I think she w/held lasix when
    she saw renal panel going up, but did not want to give much fluid. We are going
    to attempt to talk to her and see her rationale.

    Do all your coders ask for CHF specificity?




  • We are hearing that Medical Necessity is a big part of this. RAC will be
    looking at short stays (
  • I will ask for specificity if I see that chronic CHF is being treated, even if it's just to continue the home meds such as Lasix; then I ask for specificity once I know the ejection fraction. If they're not being treated for it, I won't ask for it.

    My physicians have been trained in specificity, but they're unlikely write specificity on their own if they're not treating it, so I haven't run into this problem.

    I have been known to ask physicians to update their documentation to cancel clinically inappropriate diagnoses. For instance, I have an internist who was labeling all ventilated patients whom he saw immediately post-op in the recovery room as ventilator-dependent respiratory failure. I had to pull up a number of journal articles (he is very research-oriented) to show him that this is not the documentation standard both medically and coding-wise. I'd rather take the financial hit now than deal with the repercussions later.

    Linda Renee Brown, RN, CCRN
    Clinical Documentation Specialist
    Arizona Heart Hospital
  • edited May 2016
    Can you please clarify, if you would query for the specificity of Chronic CHF. When patient continues on home lasix but not in exacerbation on the admission (being treated for something else) and you either have the EJF or not.




  • edited May 2016
    Under your example, how will you get the MD to specify whether systolic or diastolic if an EJF is not documented?

    --Juan

  • edited May 2016
    Sorry, mistake do Have EJF only. Would you still query for the Specific chf?


  • At our facility we would query only if the patient was being treated for CHF (home meds, ICD, etc) - We would not query if all we had was an EF.


  • edited May 2016
    We check for echo results, if any done w/in last 6 months. We usually print it
    out for MD to see, or write the EF on the query. Our physicians here have been
    drilled to do echo when they have a CHF patient, and none for past 6 months.
    (part of core measure)

    The problem is that if it is required for us to report CHF specificity, why are
    they asking to take that secondary dx out?




  • edited May 2016
    If an EF is on the chart and they've only documented chronic chf, we do clarify for specificity.

    --Juan


  • We follow the same guidelines as you do for CHF.

    We do not question MD diagnoses once they are documented. What we try to do is educate the physicians re: appropriate documentation based on pt condition, s/s when we do our education. We have a very old school hospital. In addition, when we were trained we were told it not CDI responsibility to question a diagnosis once it is written by the MD, however we can educate them regarding appropriate documentation when we to our inservices.


  • edited May 2016
    We look for the specificity whether acute of chronic. We search for most recent echo, and get it to the chart.

    Kim


  • edited May 2016
    We query for specificity. If we can find echo results we provide them
    for the physician's reference.



    Gina Spatafore, RN

    Clinical Documentation Integrity Specialist

    Waterbury Hospital

    203 573 7647




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