ICD-10 Consulting Must Be More than IT and Training – Clinical Documentation, Physician Engagement Key

ICD-10 consulting firms appear to be focusing on what they believe is the low hanging fruit – ICD-10 IT remediation and ICD-10 training.

Never mind that only Vendor Readiness, ICD-10, Meaningful Use, CPOE Strategies and Solutionsabout 30% of the ICD-10 transition relates to IT.   ICD-10 clinical documentation and physician engagement is the most important component of any health care providers ICD-10 plan.   And, most firms don’t understand how to do it.

First of all, a classic CDI approach is bound to fail if it isn’t sponsored by, or better yet managed or led by a physician.   There are few physicians in the U.S. that understand both how to deliver care and how to code it.  Having both a clinician and coding background gives one a unique perspective on the ICD-10 clinical documentation effort required to ensure that unspecified codes are minimized, specialty based documentation supports the ICD-10 codes, and that the high-impact specialties such as Orthopedics, OB, Cardiovascular surgery are adequately prepared for ICD-10.  Some ICD-10 consultants simply use templates.  ICD-10 consulting has led to some long, boilerplate proposals by ICD-10 consulting firms that have technical and training staff but don’t understand the finer art of documentation.  Clinical, technical, analytic perspectives are rare and needed to perform this type of engagement and do it well.

ICD-10 Consulting for health care providers should include clinical documentation that is prioritized via analytics that can look retrospectively at ICD-9 CM and ICD-9 procedure codes to see how the DRGs and documentation of medical necessity are working today. Other criteria such as unspecified codes, mapping risk, denials, volume, dollar value, specialty, service line, provider, disease categories are also considered in the review.

ICD-10 Consulting can be most valuable when one can help clinicians understand why better documentation is in their best interests, the best interests of the patient, and the best interests of the health care organization.  Once physicians realize that ICD-10 clinical documentation is their most important job with respect to the ICD-10 transition, they can let the coders do their job.  With the advent of Computerized Physician Order Entry (CPOE) and meaningful use of electronic health records, problem lists can be used to help, though by themselves problem lists don’t fully address the physician documentation issue.

ICD-10 consulting firms that don’t understand how to engage physicians are likely to be less effective.

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Michael F. Arrigo

Michael is Managing Partner & CEO of No World Borders, a leading healthcare management and IT consulting firm. He serves as an expert witness in Federal and State Court and was recently ruled as an expert by a 9th Circuit Federal Judge. He serves as a patent expert witness on intellectual property disputes, both as a Technical Expert and a Damages expert. His vision for the firm is to continue acquisition of skills and technology that support the intersection of clinical data and administrative health data where the eligibility for medically necessary care is determined. He leads a team that provides litigation consulting as well as advisory regarding medical coding, medical billing, medical bill review and HIPAA Privacy and Security best practices for healthcare clients, Meaningful Use of Electronic Health Records. He advises legal teams as an expert witness in HIPAA Privacy and Security, medical coding and billing and usual and customary cost of care, the Affordable Care Act and benefits enrollment, white collar crime, False Claims Act, Anti-Kickback, Stark Law, physician compensation, Insurance bad faith, payor-provider disputes, ERISA plan-third-party administrator disputes, third-party liability, and the Medicare Secondary Payer Act (MSPA) MMSEA Section 111 reporting. He uses these skills in disputes regarding the valuation of pharmaceuticals and drug costs and in the review and audit of pain management and opioid prescribers under state Standards and the Controlled Substances Act. He consults to venture capital and private equity firms on mHealth, Cloud Computing in Healthcare, and Software as a Service. He advises ERISA self-insured employers on cost of care and regulations. Arrigo was recently retained by the U.S. Department of Justice (DOJ) regarding a significant false claims act investigation. He has provided opinions on over $1 billion in health care claims and due diligence on over $8 billion in healthcare mergers and acquisitions. Education: UC Irvine - Economics and Computer Science, University of Southern California - Business, studies at Stanford Medical School - Biomedical Informatics, studies at Harvard Medical School - Bioethics. Trained in over 10 medical specialties in medical billing and coding. Trained by U.S. Patent and Trademark Office (USPTO) and PTAB Judges on patent statutes, rules and case law (as a non-attorney to better advise clients on Technical and Damages aspects of patent construction and claims). Mr. Arrigo has been interviewed quoted in the Wall Street Journal, New York Times, and National Public Radio, Fortune, KNX 1070 Radio, Kaiser Health News, NBC Television News, The Capitol Forum and other media outlets. See https://www.noworldborders.com/news/ and https://www.noworldborders.com/clients/ for more about the company.

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