Q&A: Including CC/MCC information on physician education materials

CDI Strategies - Volume 5, Issue 10

Q: I’ve heard different opinions between the coders and some of our CDI consultants regarding the inclusion of CC/MCC information on the educational materials we give physicians. We frequently hand out tip sheets and reference materials regarding whether a particular diagnosis constitutes a CC or MCC but some say this would be considered leading the physicians to document one way or another. We do not include this information in our physician queries, however. Are we at risk of leading the physician?

A:In my opinion, not as long as the materials are not associated with a particular patient/future claim. To my knowledge there are no rules against educating physician about MS-DRGS because it is more than a reimbursement tool. Providers need to understand how the complexity of their patients are captured by documentation of all relevant comorbidities in terms of complicating conditions (CC) and major complicating conditions (MCC).  
 
Many consulting companies, device companies, and other organizations have provider educational tools that breakdown diagnoses in terms of a CC or an MCC. Again, as long as it is provided as general education, it should be okay because providers need those pieces of information to understand how reimbursement and profiling works.
 
The trouble comes when facilities take that educational effort too far and push an agenda of artificially inflating CC/MCC capture rates to shift MS-DRG assignment to higher weighted ones.  
 
What is too far? When facilities do not simply educate physicians about the reimbursement processes and definitions, but list potential reimbursement CC/MCC designation directly on the query form with the corresponding potential relevant diagnoses.  
 
Another example is leaving a general educational tool with the breakdown of CC/MCC assignment of malnutrition diagnoses on a chart for a patient with clinical indictors of malnutrition. In both cases the information is no longer educational because it is being presented in reference to a particular patient and can, therefore, influence the provider into choosing a particular diagnosis that can impact reimbursement.  
 
Remember, in general, leading is when the provider is guided towards a particular conclusion/diagnosis by CDI or coding that results in an increase in reimbursement. In addition, it is always a good idea to review your query policies and procedures in light of the AHIMA query brief and perhaps revise any query forms that include reimbursement information.
 
Editor’s Note: ACDIS Advisory Board member Cheryl Ericson MS, RN, manager of Clinical Documentation Integrity at Medical University of (Charleston) South Carolina answered this question during the March 18 audio conference “Physician Queries: Apply Industry Guidance to Improve Procedures and Data Tracking.” Contact her at ericsonc@musc.edu.
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