By Cheryl Ericson, MS, RN, CCDS, CDIP
Let me start by saying I’m a proponent of organizational definitions. I have long advocated them as a Clinical Documentation Integrity (CDI) best practice, but I do think their purpose is frequently misunderstood. Although we like to think organizational definitions are a tool to minimize denials, they are really just an organization-wide strategy to promote consistency and have little to no bearing outside your organization.
Contrary to popular beliefs, Centers for Medicare & Medicaid Services (CMS) does not “define” conditions like sepsis or malnutrition or morbid obesity. CMS provides guidance around when a particular condition is considered medically necessary so it will be covered by Medicare through National Coverage Determinations (NCDs) (e.g., gastric bypass defining morbid obesity as a BMI of 35 with the presence of complications due to morbid obesity) or Local Coverage Determinations (LCDs). But these NCDs and LCDs do not necessarily “define” the referenced conditions when it comes to publicly reported data. The same is true for quality measures adopted by CMS.
The CMS Quality Measure titled “Severe Sepsis and Septic Shock: Management Bundle” supports best practice for the treatment of severe sepsis and septic shock which includes processes associated with Sequential Organ Failure Assessment (SOFA); however, the population eligible for this measure is defined by the assignment of either a sepsis or severe sepsis code. If you need evidence of a lack of CMS guidance defining a particular condition, look no further than the recent Office of the Inspector General (OIG) findings related to severe malnutrition where the OIG audited cases to “determine whether providers are complying with Medicare billing requirements when assigning diagnosis codes for the treatment of severe types of malnutrition on inpatient hospital claims” (https://oig.hhs.gov/reports-and-publications/workplan/summary/wp-summary-0000258.asp). It is even hard to pin down commercial payers other than CMS when it comes to defining conditions. Often organizations receive information informing them a diagnosis was removed with little, if any explanation, of the criteria used to make that determination.
So why bother with organizational definitions? To promote consistency across physicians, CDI professionals and Coding professionals. Often organizational definitions are a great way to engage physician leadership so they can become CDI advocates and to train CDIs. The reality is that making a diagnosis is a complex process and there is often disagreement across providers treating the same patient. Something else to consider is whether or not organizational definitions are too stringent and promote under-coding within an organization which can negatively impact financial goals. Just think about the debates that are occurring within the CDI profession over the use of Systemic Inflammatory Response Syndrome (SIRS) criteria vs. SOFA criteria for sepsis. Many organizations made the shift to SOFA criteria when it was first released only to return to SIRS criteria after the volume of sepsis cases decreased within their organization due to the stricter criteria. And what about those diagnoses that don’t have an organizational definition? What criteria should be used? Are we getting too bogged down in discussions about how to define a condition that we can’t see the forest from the trees? In fact, the whole concept of clinical criteria was such an issue within the CDI and Coding professions that the Official Coding Guidelines added the Coding Assignment and Clinical Criteria guideline a couple of years ago:
“The assignment of a diagnosis code is based on the provider’s diagnostic statement that the condition exists. The provider’s statement that the patient has a particular condition is sufficient. Code assignment is not based on clinical criteria used by the provider to establish the diagnosis.” (ICD-10-CM Official Guidelines for Coding and Reporting (FY 2021), Page 12 of 126).
Although this guideline was intended to provide clarity, I really think it just added another layer of confusion as some organizations mistook this advice as an excuse to stop clinically validating documented diagnoses. Really, this guideline only separated the coding function from the medical necessity function because those lines were getting blurred; however, the medical necessity requirement is still alive and well as demonstrated by OIG audits.
It was once believed that organizational definitions could be helpful from a compliance standpoint, but that only occurs when the definitions are consistently used across all payers and for all situations. Unfortunately, what I’ve seen over the years is that CDI professionals often have one rigorous set of criteria they use before querying for a potentially missing diagnosis and a different threshold for clinical validation e.g., if the provider documents a diagnosis based on limited criteria. I get it, most CFOs view CDI departments through a financial lens and few CDI departments want to be responsible for removing a diagnosis complication/comorbidity (CC) or major complication/comorbidity (MCC), but this inconsistency is confusing and increases compliance risk.
So that begs the question, “Have organizational definitions outlived their usefulness?” Perhaps it is time to re-evaluate the purpose of organizational definitions. Are they resulting in more harm than good? In particular, perform an analysis to determine if organizational definitions are yielding the desired impact, which is typically fewer denials. In addition, determine if organizational definitions have actually become a liability due to inconsistent application, or potentially leading to under-coding of valid diagnoses. Organizational definitions can be a great educational tool for CDI professionals, Coding professionals and providers, but they often have limited practical application outside of your organization, so be sure to evaluate their usefulness on a regular basis.