Note from the ACDIS Director: ACDIS Regulatory Committee—the voice of CDI advocacy

by Brian Murphy

It’s easy to complain about CMS rules, regulations, and coding guidance from the likes of the Cooperating Parties or the American Hospital Association’s (AHA) Coding Clinic. Certainly, over the years we’ve seen guidance we’ve disagreed with, or believed to be arbitrary or incongruent with clinical practice.

But complaining is ultimately empty and counterproductive, and a guarantee that nothing will change. On the other hand, you can do something about it, like the great work the ACDIS Regulatory Committee is doing.

This group of volunteers, led by Howard Rodenberg, MD, MPH, CCDS, chair of the ACDIS Regulatory Committee and the CDI physician advisor at Baptist Health in Jacksonville, Florida, keeps a busy schedule. Under the ACDIS banner, they meet monthly to discuss the latest regulatory, coding, and clinical releases from the nation’s authorities, distill the guidance, and ask the right questions while offering input either informally or during the official comment periods.

In CDI terms, think of the Regulatory Committee’s work as a query. Except, instead aiming at clarifying a diagnosis or procedure, the goal is to help make the working blueprints for the CDI profession more understandable and user-friendly.

You can find the Regulatory Committee’s work in the “Thought Leadership” dropdown in the main menu of the ACDIS website.

I took a few minutes this week to get caught up with Rodenberg, which as usual was a delight (he’s funny, invested in his work, and just plain interesting). He is also humble, and gratefully acknowledged the work of his predecessor, former chair Candace Blankenship, RN, BSN, CCDS, CDI specialist at Mayo Clinic in Jacksonville, Florida.

“When I think about where this committee came from, it never would have existed without Candace Blankenship. I stand on her shoulders and the infrastructure she laid,” he said. “I’ve been fortunate to take the next step and operationalize that and participate in these processes. I think the last year of my tenure has been taking the next step. And whoever takes over from me will hopefully take the next step.”

Rodenberg also spoke highly of the Committee’s team of volunteers, from whom he finds himself learning something new at every meeting, if not daily.

“It’s a great group of volunteers, and it has the whole spectrum of people involved in CDI practice—physicians, nurses, coding professionals, as well as institutions, academic environments, consulting environments—because the regulatory process affects everyone, not just a piece of the pie,” Rodenberg said. “There’s virtually nothing we’ve heard of that someone doesn’t know something about. I’ve learned much more from that team than I’ve contributed. It’s a learning experience.”

In addition to commentary to the likes of CMS, the AHA, and the National Center for Health Statistics (NCHS), Rodenberg notes that the committee has developed additional helpful tools for the ACDIS membership. These include a regulatory map of how to comment to CMS and a quality worksheet with references to appropriate regulations including hospital-acquired conditions (HAC) and patient safety indicators (PSI).

“These are their ideas, and I’m privileged to lead the discussion,” he said. “They’ve contributed much more outside of what you think of as the regulatory process.”

As for what he is most proud of and what he hopes the Regulatory Committee’s work will yield, Rodenberg said that building connections among policymakers, and giving CDI professionals a voice at the table, are among them.

“As a whole, it’s seeing the progress and being part of the process, moving things ahead, and making ACDIS an entity in that process. We’ve established contacts in CMS and CDC and NCHS. Now they know us,” he said. “We’ve put together some relationships I’m proud of. I’m proud of setting that table so the next folks in the committee can keep running with this.”

He does hope that ACDIS members take the time to comment to CMS on their own, and become comfortable with the rulemaking and comment process. The more voices CMS and the AHA hear, the better, he says.

“Rather than the ACDIS membership being aware of what we’re doing, we’d rather the membership be aware of the process—how to listen to the ICD-10-CM Coordination and Maintenance committee meetings and the IPPS public comment period,” Rodenberg said. “If the members learn the process, that’s what I want them to know—not necessarily hearing from us. Everything else we do is icing on the cake. I really am heartened that CMS seems to listen. You don’t always get what you want, but they listen, and that’s worth a ton.”

We’ve seen first-hand CMS take into account ACDIS commentary in its recent rulemaking, and that’s due to the efforts of the Regulatory Committee. Thanks again to Rodenberg and this great group for their outstanding efforts.

Editor’s note: Murphy is the director of ACDIS. Contact him at bmurphy@acdis.org.