Tip: Use the OIG Work Plan to focus your CDI efforts
Those who’ve worked in CDI or healthcare compliance for any length of time typically prepare themselves for the annual October release of the Office of the Inspector General’s (OIG) Work Plan. The thousand-plus-page document outlines OIG targets for the coming year complete with a synopsis of why the agency feels each area of concern represents an area worth auditing.
And, if the OIG thinks a topic represents a concern, CDI professionals should too.
In 2017, however, the OIG changed tactics and is now releasing its auditing priorities on a monthly schedule, making it more difficult for the average CDI professional to keep up with. Nonetheless, keeping up with the OIG’s monthly Work Plan updates is worth the time as it may help safe guard your facility against costly audits and denials down the line.
All the active Work Plan items can be accessed on the OIG’s website and they can be searched using any term you’re curious about. For CDI, perhaps try searching for “documentation,” “coding,” or a specific problem diagnosis such as malnutrition. This will bring up all the active items mentioning that term.
Currently, there are a couple items that CDI professionals should be aware of on the docket. First, there are two separate items related to payments for malnutrition diagnoses: One directly related to the diagnosis of kwashiorkor (a form of malnutrition rarely encountered in the United States), and another related to the diagnosis of severe malnutrition.
Secondly, the OIG has an active Work Plan item related risk-adjustment data and supportive documentation for Medicare Advantage patients. This item includes a review of medical records to ensure that the documentation supports the diagnosis submitted on the claims for risk adjustment payments.