CDI Reporting Structure

In a recent post to the ACDIS LinkedIn page titled CDI-Grow or Die I pointed out the numerous inherent shortcomings to our present CDI processes including highlighting the fact that we are misdirected and unrelentingly focused upon reimbursement as an outcome of our efforts at documentation improvement. In reality, our energies should be focused upon affecting positive change in physician behavior patterns of documentation for the best communication of patient care regardless of setting or level of care of hospitalized patient. I attribute this misdirection and unwavering focus upon reimbursement on CDI consulting companies that sell CFOs on the "additional cash" CDI programs can generate if only the CFO signs on the dotted line and commits the hospital to paying an outlandish amount for a low value bill of goods.  CFOs, looking for additional cash in a tough precarious revenue predicament with costs to operate increasing and reimbursement decreasing, is enticed and willingly agrees to CDI consulting pushing their "query"marching orders upon fellow CDI professionals with their untenable expectation of 25 to 30 chart reviews a day and query rate upwards of 30%. Totally ridiculous.

I wanted to gauge CDI specialist's thoughts upon CDI reporting to the Physician Advisor, VP Medical Affairs or Chief Medical Officer as opposed to HIM, Case Management, Quality, VP Revenue Cycle or CFO, etc. Why, you may ask? First off, physicians are a smart, analytical and systematic group of individuals who will see right through CDI consulting company's unsubstantiated promises and claims to generate revenue, recognizing that clinical documentation serves a major purpose of best communicating patient care. A by-product of sound effective documentation is accurate reimbursement the hospital is entitled to based upon care provided, supported and substantiated by good principles of documentation. CDI programs should be created by, directed by, run by physicians geared towards physicians and their practice of median as opposed to finance people being fed fallacies, white lies and Kool-Aid by slick sales people employed by CDI consulting companies with their even slicker software meant to demonstrate to finance people (CFOs) supposedly how much monies they are generating by relegating our responsibilities to that of "tasked queries" as opposed to roles of facilitators of documentation process improvement through knowledge sharing of best practices and principles of documentation with physicians that stand the test of time.  

What are your thoughts and comments. I am very interested in hearing from you all.


  • Hi, Glenn

    Let me say I don't disagree w/ your major premise.  But, I do believe , just as w/ people, there are capable and ethical consulting firms that advocate for compliant CDI Practice as per the letter and intent of CDI Best Practice Standards.   I feel we should employ CDI practice that enhances the 'clinical truth', ensure proper reporting of Risk Factors, strengthens documentation, and so forth.  When this is done, complaint billing follows.  I concur there are some CDI Consulting Firms (they contact me) that focus on the revenue and makes all sorts of claims about the fountain of wealth they can unleash.  But, I also know there are some consulting firms that 'get it', and offer valuable services and state of the art CDI practice.

    I personally feel the best place for CDI to report includes the Quality Dept...and I note you excluded them.  I can tell you that I am in Quality, and it is wonderful in regards to CDI practice...we work quite a bit on issues germane to quality factors, and most of our work does not impact $$.  (Enough to justify our existence, but by no means our sole focus).  I would like to hear what others may feel as well.  But, yes, I agree w/ your premise that some in the industry do contact various Executives and engage in hyperbole in regards to the purpose and practice of CDI to the detriment of the industry; I certainly concur I find it dubious when one makes concrete and rigid claims regarding expectations of CDI, such as the number of cases we must review, an absolute query rate %, and so on.

    Paul Evans, RHIA, CCDS, CCS, CCS-P

  • Paul, thank you for your comments, well put and well received on my end.

  • Glen:  Call me sometime - would love to talk to you in person.  You are offer very detailed and pertinent insights into CDI.


  • I have to say I agree with you both. The main function of CDI should be accurate and clear documentation illustrating the complexity of your patients and the resources required to treat them while maintaining compliance and supporting that evidence-based care was provided. I am with Paul: best place for CDI is under quality. That way the functions and goals remain clearly defined and quality is always the ultimate goal. CDI should affect change in documentation practices by educating providers and assisting them in navigating the ever-changing rules and regulations of our industry.

    I'm not sure the people choosing which consulting firms they should hire understand CDI and how it
    can best be used. Like Glenn said, they are easily wooed by claims of large financial return. My hope is that as our industry grows, more physicians and hospital administrators will come to value our role for all the right reasons.
  • Hi Glenn, 

    It would be great if CDI could report to the VP of Medical Affairs or the Chief Medical Officer.  It would be even greater if the issue of reimbursement wasn’t also on their list of priorities. 

    My guess is that they would tell you they have their hands full with quality initiatives, implementation of policies and procedures, credentialing of medical staff, committees, etc., etc.  And, unfortunately they are also being pressured to join in the business of ever increasing reimbursement for the institution.   

    We are in the era of bundled payments, Hospital Value Based Purchasing, Accountable Care Organizations and Hierarchical Condition Categories.  The HCC data are used to calculate an HCC risk adjustment factor for an entire year of encounters across the continuum of care.   The education being done by consultants is not just in hospitals, but also in physician offices and outpatient settings.  I’m sure the teaching includes something to the effect that “the sicker the patient is, the more reimbursement will be available for all.”  Additionally, physicians are likely being educated that in order to bill the more complex E/M codes they need to document greater acuity.   So, physicians who come into the hospital are already pretty savvy about how they should document to increase reimbursement.   Everyone is concerned with getting his or her share of the reimbursement pie. 

    You wouldn’t believe how many times, when I approach a physician on the floor about documentation, I am asked, “what kind of documentation will bring more reimbursement.”    I always reply that it’s about what is appropriate, accurate, and true.  

    My point is that although physicians are a smart and  analytical group of individuals, they are also  human and worry about paying for medical school loans, office overhead, lifestyle, etc.  Still, our best hope lies with them. 

    Katherine Peterson, RN/CCDS


  • Lots of great insight- however even if the focus is quality there will be a financial impact especially in todays system- I do not think that you can separate quality from reimbursement. I try to tell my providers that if we make sure we have the most accurate and well documented record the reimbursement will be there, right along side the great quality profile that they want.

    Barbette Welsh RN,BSN,CCDS

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