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 Arrigo brings four decades of experience in the software, financial services, and healthcare industries. In 2000, Mr. Arrigo founded No World Borders, a healthcare data, regulations, and economics firm with clients in the pharmaceutical, medical device, hospital, surgical center, physician group, diagnostic imaging, genetic testing, health IT, and health insurance markets. His expertise spans the federal health programs Medicare and Medicaid and private insurance. He advises Medicare Advantage Organizations who provide health insurance under Part C of the Medicare Act. Mr. Arrigo serves as an expert witness regarding medical coding and medical billing, fraud damages, as well as electronic health record software for the U.S. Department of Justice. He has valued well over $1 billion in medical billings in personal injury liens, medical malpractice, insurance fraud cases. The U.S. Court of Appeals considered Mr. Arrigo's opinion regarding loss amounts, vacating, and remanding sentencing in a fraud case. Mr. Arrigo provides expertise in the Medicare Secondary Payer Act, Medicare LCDs, anti-trust litigation, medical intellectual property and trade secrets, HIPAA privacy, health care electronic claim data Standards, physician compensation, Anti-Kickback Statute, Stark law, the Affordable Care Act, False Claims Act, and the ARRA HITECH Act. Arrigo advises investors on merger and acquisition (M&A) diligence in the healthcare industry on transactions cumulatively valued at over $1 billion. Mr. Arrigo spent over ten years in Silicon Valley software firms in roles from Product Manager to CEO. He was product manager for a leading-edge database technology joint venture that became commercialized as Microsoft SQL Server, Vice President of Marketing for a software company when it grew from under $2 million in revenue to a $50 million acquisition by a company now merged into Cincom Systems, hired by private equity investors to serve as Vice President of Marketing for a secure email software company until its acquisition and multi $million investor exit by a company now merged into Axway Software SA (Euronext: AXW.PA), and CEO of one of the first cloud-based billing software companies, licensing its technology to Citrix Systems (NASDAQ: CTXS). Later, before entering the healthcare industry, he joined Fortune 500 company Fidelity National Financial (NYSE: FNF) as a Vice President, overseeing eCommerce solutions for the mortgage banking industry. While serving as a Vice President at Fortune 500 company First American Financial (NYSE: FAF), he oversaw eCommerce and regulatory compliance technology initiatives for top ten mortgage banks and led the Sarbanes Oxley Act Section 302 internal controls IT audit for the company, supporting Section 404 of the Sarbanes Oxley Act. Mr. Arrigo earned his Bachelor of Science in Business Administration from the University of Southern California. Before that, he studied computer science, statistics, and economics at the University of California, Irvine. His post-graduate studies include biomedical ethics at Harvard Medical School, biomedical informatics at Stanford Medical School, blockchain and crypto economics at the Massachusetts Institute of Technology, and training as a Certified Professional Medical Auditor (CPMA). Mr. Arrigo is qualified to serve as a director due to his experience in healthcare data, regulations, and economics, his leadership roles in software and financial services public companies, and his healthcare M&A diligence and public company regulatory experience. Mr. Arrigo is quoted in The Wall Street Journal, Fortune Magazine, Kaiser Health News, Consumer Affairs, National Public Radio (NPR), NBC News Houston, USA Today / Milwaukee Journal Sentinel, Medical Economics, Capitol ForumThe Daily Beast, the Lund Report, Inside Higher Ed, New England Psychologist, and other press and media outlets. He authored a peer-reviewed article regarding clinical documentation quality to support accurate medical coding, billing, and good patient care, published by Healthcare Financial Management Association (HFMA) and is published in Healthcare IT News.

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