News: Vidant provides firm rebuttal to OIG findings related to malnutrition

Accused of misreporting malnutrition in a January 2017 OIG audit, Vidant Medical Center, a 909 bed acute care teaching hospital, fought back with a collaborative rebuttal of the findings published alongside the original audit results.

The OIG found Vidant owed $1,403,132 in improper payments for codes 261 and 262 relating to malnutrition marasmus. Vidant refuted each OIG claim in turn, step-by-step, highlighting CMS’ auditors lack of uniform clinical criteria and demonstrating its own industry-supported criteria for malnutrition diagnoses.

“Reviewers failed to use any identifiable guidelines for the assessment and diagnosis of malnutrition, such as the Academy of Nutrition and Dietetics (AND)/American Society for Parenteral and Enteral Nutrition (ASPEN) Guidelines,” Vidant’s rebuttal states.

“Marrying the clinical and coding requirements was a really strong part of their rebuttal,” Cheryl Ericson, MS, RN, CCDS, CDIP, manager of clinical documentation services for DHG Healthcare in Charlotte, North Carolina, said during last week’s ACDIS Quarterly Conference call. “It’s great that Vidant says they use ASPEN criteria.”

Facilities should establish set criteria for difficult diagnoses. For malnutrition, ASPEN represents a national standard although facilities can work with their physicians, coders, and CDI professionals to define clinical standards for their use incorporating appropriate references and supportive documentation. “You do need a consensus for the criteria you’re using though,” Ericson said.

Additionally, Vidant’s rebuttal took a collaborative approach, bringing “a team of more than 20 people, including physicians, HIM representatives, coders, dietitians, and compliance experts,” who carefully reviewed all 100 claims included in the OIG sample. The rebuttal complains that its team of 20 “spent close to four full days with them reviewing on a chart-by-chart basis” when the OIG auditors came onsite the week of June 6, 2016.

“The collaboration amongst the team with the rebuttal is really good for the industry,” Anny Yuen, RHIA, CCS, CCDE, CIP, VP of revenue cycle at R3 Health Solutions in Miami, Florida, said during the Quarterly Call. There was a time when CDI specialists tended to work in silos, but the best approach to an audit rebuttal is through collaboration.

Nevertheless, after reviewing the hospital’s comments, the OIG maintained that its findings and recommendations were valid for all 89 claims found to be in error.

Editor’s Note: To read the full OIG audit report and Vidant’s rebuttal, click here. To listen to the ACDIS Quarterly Conference Call and hear the further discussion amongst the board on this topic, click here.