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Implementing Outpatient CDI Across the Enterprise

Judy Moreau, MBA, RNVP Mid‐Revenue Cycle Trinity HealthLivonia, MI

Andrea Eastwood, BAS, RHIADirector Clinical Encounter and Documentation ExcellenceTrinity HealthLivonia, MI

2019 Copyright, HCPro, a division of Simplify Compliance LLC, and/or session presenter(s). All rights reserved. These materials may not be copied without written permission.

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Learning Objectives

• At the completion of this educational activity, the learner will be able to:– Gain an understanding of how Trinity Health is structuring oversight of outpatient CDI to ensure success

– See how an enterprise approach can be utilized for implementation of outpatient CDI at a single or multi‐facility organization

– Gain an understanding of the key roles and responsibilities to ensure successful outpatient CDI in the acute care setting

– Gain an understanding of baseline data needed to track the impact of outpatient CDI work efforts as well as the financial benefit

– Gain an understanding of the outpatient CDI playbook created by Trinity Health to aid its facilities with implementation in the acute care setting


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Trinity Health’s 22‐State Diversified System Today

94 hospitals in 22 states (owned, managed, or in JOAs or JVs)$18.3B in revenue1.5M attributed lives$1.1B community benefit ministry133,000 colleagues7,800 employed physicians and clinicians28,000 affiliated physicians23 clinically integrated networks109 continuing care locations


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Trinity Health’s Mission, Vision, and Core Values

Our mission We, Trinity Health, serve together in the spirit of the Gospel as a compassionate and transforming healing

presence within our communities.Our core values• Reverence• Commitment to those

who are poor• Justice• Stewardship• Integrity

Our visionAs a mission‐driven innovative health organization, we will become the national leader in improving the health of our

communities and each person we serve. We will be the most trusted health partner for life.


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Trinity Health’s Approach to Outpatient CDI


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Outpatient CDI: Not as Straightforward as Inpatient Programs

Challenges• No clear definition on what encompasses

outpatient CDI – acute setting vs. physician practice

• Difficult to determine “true owner” of outpatient CDI

• No all‐encompassing OP CDI implementation plan since it crosses multiple departments/disciplines

• No industry standards, metrics, benchmarks, best practices because most organizations in early stages of implementation

• Data to support outpatient program resides in multiple software applications across Trinity Health and our sites

Trinity Health Position• Revenue excellence should be responsible

for all CDI activities across the continuum• Implementation plans should be site

specific and dependent upon outpatient area identified with greatest opportunity

• Metrics will need to be site specific and dependent upon the issue the site is trying to improve/correct, such as converting observation cases with length of stay greater than 24 hours to inpatients

• Educate sites on data available in each software application and how to generate and interpret reports


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Outpatient Strategy Requires Collaboration

• Outpatient charge capture & CDI workgroup team includes:– Corporate office CDI – Corporate office revenue integrity – Representatives from our sites in the areas of coding, CDI, and revenue integrity/charging

• Workgroup developed strategy and implementation guidelines in time for the start of the new fiscal year, which began July 1, 2018


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Oversight Structure: Overcoming Obstacles

• The Trinity Health CDI executive oversight committee – Served as the oversight committee for inpatient – Now has responsibility for outpatient CDI

• The CDI executive oversight committee membership includes:– Chief financial officer of operations– Chief clinical officer– TH CMIO– TH CMO– TH integrity and compliance VP– Mid revenue cycle VP– Corporate office CDI and HIM directors


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Executive Leadership Education

• Share key reasons for shift of services from inpatient to outpatient – Changes to CMS payment methodologies– Benefits to improving documentation in the outpatient setting– Examples of how documentation might be improved in key areas:

• Observation services – do patients staying 36–48 hours meet inpatient criteria, assignment of correct observation HCPCS code, ancillary services carve‐out

• Physician practices – accurate documentation of comorbid conditions to support HCC and RAF scores

• Emergency department – accurate capture of facility‐level ED charges, improved documentation of infusions and injections, improved accuracy of present on admission indicators, observation start times, medical necessity of and solidification of patient status

• Outpatient diagnostics/ambulatory clinics – improved documentation of infusions and injection start and stop times, screening vs. diagnostic study, accuracy of wound, size and debridement type, diagnosis code supports need for testing


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A Phased Approach Strategy for Implementation

• Phase I(a): Hospital‐based outpatient services – Begin analysis phase July 1, 2018 to identify departments with greatest opportunities or

quick wins– All sites to implement at least 1–2 outpatient CDI initiative(s) by the end of FY19– Implement across multiple departments in FY20

• Phase I(b): Trinity Health provider network– Work currently underway to develop program for better capture of comorbid conditions in

limited populations that are part of an ACO or integrated clinical network– Managed by different leadership team

• Phase II: Trinity‐owned outpatient surgery centers and clinics (non‐provider based) – Targeted implementation date – TBD


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Directed Sites’ Focus on Key Hospital Outpatient Departments

• Sites to perform data analysis and identify where to focus initial efforts– Emergency department– Observation – Cardiology (including cath lab) – Radiology (including interventional radiology)– Laboratory – Outpatient surgery/procedure and bariatric surgery– Infusion clinics/areas within the hospital– Ambulatory clinics (pain clinic, wound clinic, coagulation clinic, neuro, cancer, dietary, OB)

– Urgent care (hospital based)


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Implementation and Timeline and Expectations for FY19

FY19 Timeline Expectation

1st quarter • Select 1–2 areas to begin OP CDI in FY19• Conduct analysis to identify opportunities• Work with system office on considerations and options when site staffing resources may

not be available for OP CDI

2nd quarter • Identify key stakeholders for initiative(s) selected• Develop plan and target for improvements• Outline metrics and ongoing monitoring • Obtain approval from system office CDI on plan, initiatives, metrics, and monitoring

3rd quarter • Implement plan for FY19• Collect and track metrics comparing to target

4th quarter • Collect and track metrics comparing to target


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FY19 Outpatient CDI Initiative Checklist

• The initiative checklist provides a high‐level outline of key activities to initiate an outpatient CDI, which can be modified to fit the RHM needs.

• Starts with local determination of an area of focus (ED or observation, or other area approved by S.O.) – based on data.

• Data, analysis, and identification of financial opportunity has to be done at the RHM level. Regional CDI managers can support data analysis and estimate potential financial benefit, but they will need help with local data resource.

©2017 Trinity Health

Outpatient CDI Initiative ChecklistBased on data analysis, pick the hospital‐based outpatient area(s) to investigate for potential opportunity and focus (ED or observation recommended, other areas may be selected pending approval of S.O.): Review that area's list of "potential areas of focus" in the OP CDI playbook to jumpstart ideas Run baseline data Outline goals and objectives for improvements – i.e. reduction in observation case LOS;

documentation supporting accurate E/M level in ED Determine proposed financial and other benefits

Determine outpatient CDI staffing resources and skill set(s) needed for initiative identified.

Determine if any education is needed to support initiative and provide education if applicable.

Determine if education is needed with service area (observation or ED) – provide education.

Determine technology, tools, and reports available that will support the initiative selected.

Track/document workflow changes or education that has taken place as part of the initiative.

Outline metrics that will be tracked and monitored as well as the frequency of monitoring.

Begin initiatives/new processes.

Track and monitor metrics and progress towards goals.

Provide updates to the CDI oversight committee and all key stakeholders.

Continue to revisit data analysis to identify new/additional opportunities and initiatives.


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Outpatient CDI Program in FY20

• Set requirement that sites begin working on developing the scope of a full outpatient CDI program for implementation in FY20 to include:– Conducting analysis of additional areas of opportunity and focus– Determining staffing needs to support outpatient CDI for inclusion in FY20 budget planning

– Noting that scale and scope of outpatient CDI for each site will be dependent upon its size and opportunities identified

– Pre‐work for FY20 is expected to be completed by June 2019


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Outpatient CDI Program Implementation Checklist

Determine OP CDI program structure, roles, and responsibilities: Executive champion OP CDI director/leader OP CDI oversight committeeKey stakeholdersPick the hospital‐based outpatient area(s) to investigate for potential opportunity and focus: Run baseline data Identify priority initiatives Outline goals and objectives for improvements Determine financial and other benefits

Determine outpatient CDI staffing resources and skill set(s) needed for initiatives identified. Provide role specific education if applicable.

Outline reporting structure for outpatient CDI roles.

Educate outpatient CDI Team on outpatient CDI scope and the objectives identified.

Determine technology, tools, and reports available that will support the team in achieving the objectives.Outline metrics that will be tracked and monitored as well as the frequency of monitoring.

Outline proposed workflow and collaboration touch points amongst team and communicate to all key stakeholders. Include how reviews and/or work will be tracked.

Begin initiatives/new processes.

Track and monitor metrics and progress towards goals.

Provide updates to the oversight committee and all key stakeholders.

Continue to revisit data analysis to identify new/additional opportunities and initiatives.

FY20 Outpatient CDI Program Implementation Checklist

• The implementation checklist provides a high‐level outline of key activities that can help start the work effort of outlining an OP CDI program. These can be modified to fit the RHM needs.

• Starts with local discussions to determine RHM executive champion and who will have responsibility to oversee OP CDI program (OP CDI director or leader).

• Data analysis and identification of financial opportunity has to be done at the RHM level. Regional CDI managers can support data analysis and estimate potential financial benefit, but they will need help with local data resource.

• Need to identify additional resource requirements required for FY20 early in CY19 so that resources can be appropriately budgeted.


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Trinity Health Sites Are in Various Stages

• Sites are required to identify 1–2 areas in which they will implement outpatient CDI in FY19– 20 hospitals are implementing observation CDI

• 3 have had observation CDI in place since 2016– 4 hospitals are implementing ED CDI – 5 hospitals are implementing OP CDI in the outpatient surgery/surgery charging– 2 hospitals are implementing OP CDI in the pro fee coding area as the HIM/CDI director has responsibility for pro fee coding

– 1 hospital is implementing OP CDI in the cardiac cath lab area– 1 hospital is implementing in the OP CDI in the clinic area– 1 hospital is implementing in OP CDI in cancer center – 9 hospitals are still undecided, in the data analysis phase, or have not yet begun


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Outpatient CDI Playbook and Tools Overview


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Outpatient CDI Playbook

• The playbook contains an introductory overview of outpatient CDI that includes:– List of items to investigate to determine the areas that would benefit the most from improved documentation

– Outline of outpatient CDI program roles and responsibilities

• The playbook is then structured in chapters for each of the outpatient areas addressed– Each chapter is to be used as an implementation guide for that area of focus


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General Overview Section

• Consider high revenue, high volume, high rejection rates, high unbilled and bill hold rates• Data review of outpatient national coverage determination (NCD) and local coverage

determination (LCD) edits • Review of Ambulatory Payment Classification (APC) errors• Focused documentation chart reviews to identify potential opportunities• Querying processes for diagnosis specificity and/or comorbid conditions • Charge capture reviews and errors• Job shadowing and process reviews – at department level to identify workflow and

documentation gaps • Review ambulatory surgery levels to ensure they are updated with advances in equipment and

surgical charging criteria• Areas of compliance risk• Reimbursement opportunity• Review of denials


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Metrics to Track Financial Benefits

• Obtaining baseline data is a critical first step in tracking the return on investment of the outpatient CDI program and will be used to track improvements and financial impact of the work effort in FY19 and beyond

• Baseline data can be captured on either a monthly or annual average • It is important to identify the system and reports that will be used and secure resources to generate the data on an ongoing basis, which for Trinity can vary by site

• Sites are directed to use the list of suggestions noted in each chapter to determine baseline data and potential financial opportunity, and to track the ongoing impact for the initiative(s) selected


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Examples of Baseline Data to Determine Benefit

• Example of baseline data for hours in observation status:

Denial reduction formula:• Baseline denials for period – (minus) Current denial for period = Improved

revenue


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Establishing Local Structure to Support Outpatient Initiatives

• The following roles have been identified as key to an outpatient CDI program:– Outpatient CDI executive sponsor– Director/leader of outpatient CDI– Outpatient CDI oversight committee


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Outpatient CDI Executive Sponsor Role

• The executive sponsor ensures the program has adequate resources and removes barriers to ensure program success.

• Recommend the chief financial officer (CFO) or chief operation officer (COO) serve as the executive sponsor. (See Appendix for sample role expectations.)

• It is essential that the individual in this role have the authority to remove barriers across the various departments with outpatient CDI responsibilities.


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Director/Leader Position

• The site director is responsible for developing the outpatient strategy in coordination with the system office as well as monitoring performance.

• Recommend this role report directly to the executive sponsor for outpatient CDI responsibilities. (See appendix for sample role expectations.)

• Consider the following roles to direct outpatient CDI:– Director of revenue optimization– Director of health information management– Director of clinical documentation improvement – Director of chargemaster or revenue integrity

• It is essential that the individual in this role be able to direct initiatives and collaborate across the various departments that have outpatient CDI responsibilities.


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Oversight Committees Role

• It is strongly recommended that the site set up an oversight committee whose purpose is to monitor program activities, make recommendations, remove barriers, and champion the program.– Sites may elect to add outpatient CDI to an existing committee. – Membership would include the executive sponsor, director of outpatient CDI, and key stakeholders across all departments included in the outpatient CDI program's areas of focus. (See appendix for sample committee structure and membership.)


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Playbook as Implementation Plan

• Each chapter serves as a mini implementation plan:– Outlining initial scope for the areas selected (e.g., ED, observation, ancillary areas, etc.)

– List of potential areas of focus to prioritize initiatives– Guidance on collecting baseline data and estimating potential financial benefit– Outline of key roles and list of specific skill sets needed – Reminder to document the workflow and collaboration that will occur amongst the team

– Identification of metrics that will be monitored and how they will be collected– Tracking metrics and financial benefit


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Observation CDI Chapter Example

• Sites are given a suggested scope for observation CDI but can adjust the scope as needed to fit site‐specific needs– Observation CDI scope should encompass:

• Patients placed in observation status• Observation patients regardless of location in the hospital (dedicated observation unit, inpatient unit, ED)


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List of Potential Opportunities

• Observation patients with stays over 36–48 hours – do these patients meet inpatient criteria?

• Correct patient status (observation vs. inpatient, 2‐midnight rule)• Delivery of Medicare Outpatient Observation Notification (MOON) instructions (compliance impact)

• Observation status record content – clarification of documentation and diagnosis specificity

• Failing to convert observation status to inpatient admission due to lack of documented medical necessity and/or lack of order for inpatient admission


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Possible Observation Areas of Focus

• Direct placement to observation status– Admit source documentation – Capture G code (G0379) for direct placement to observation from physician office– Capture G code (G0463) for direct placement to observation from an external site or ED

– Fiscal intermediary guidance on billing for direct placement to observation

• Clear definitions of extended recovery vs. observation status • Documenting injections and start and stop times for infusions


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Possible Observation Areas of Focus (cont.)

• Observation charging hours – Inconsistent capture of carve‐out hours in observation; capture of in/out time patient is away in an ancillary department

– Documentation of active monitoring of services or procedures provided during observation status

– Consistent application of when patient time in observation status starts/ends• Site process for patients in observation status less than 31 minutes total as these will trigger edits

• Denials related to observation cases• Awareness that the time a patient spends in observation status does not count toward the three days inpatient status to qualify for skilled nursing facility (SNF) benefits under Medicare


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Benefits of Observation CDI Outline

• Accurate reflection of patient acuity, severity of illness, and risk of mortality

• Correct patient status/type– Medicare patients in an inpatient status do not incur the financial burden of Part B deductibles and coinsurance

• Observation comprehensive APC – dependent upon correct charging (Medicare)

• Improved reimbursement for cases appropriately converted to inpatient status

• Correct charging • Denial avoidance


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Key Skill Sets and Reporting Structure

• Observation department clinical documentation review (clinical documentation specialists)

• Charge entry (revenue coordinators) • Coding/edit review • Revenue integrity chargemaster (revenue liaison or CDM coordinator) • Not likely that one person will possess all the skills needed – it will take a team!


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Observation Clinical Documentation Review (Clinical Documentation Specialists) Skill Set

• To be effective in observation CDI, the staff member should have knowledge of:– Inpatient CDI core training and documentation strategies – Diagnosis coding guidelines in outpatient setting– Current Procedural Terminology (CPT®) codes– HCPCS codes – APCs – 2‐midnight rule– HCC risk adjustment


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Observation Clinical Documentation Review (Clinical Documentation Specialists) Skill Set (cont.)

• To be effective in observation CDI, the staff member should have knowledge of:– Charging and patient type processes at the facility

– Compliant query practices– Admission criteria used at facility (InterQual, Milliman)

– Condition codes 44 and W2 processes

– Pathophysiology, clinical conditions, disease processes

• To be effective in observation CDI, the staff member should also have skills such as:– Ability to work well and collaborate with other departments (case management, nursing)

– Ability to communicate well verbally and in writing

– Ongoing love of learning– Ability to teach


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Charge Entry (Revenue Coordinators) Skill Set

• To be effective in this role, the revenue coordinators should have the following knowledge of, and ability to: – Edits and regulations – Outpatient coding tool referral process – Charging process – CPT codes– HCPCS codes – 2‐midnight rule guidelines– Condition codes 44 and W2 process – Work well and collaborate with other departments (case management, nursing)– Communicate well verbally and in writing


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Outpatient Coder Skill Set

• To be effective in this role, the outpatient coders should have the following knowledge of, and ability to: – Edits and regulations – Outpatient coding tool referral process– Charging process – Diagnosis coding guidelines in

outpatient setting– CPT codes– HCPCS codes – APCs

– 2‐midnight rule guidelines– General knowledge of charging and

patient type processes at the facility– Compliant query training– Ability to work well and collaborate

with other departments (case management, nursing)

– Ability to communicate well verbally and in writing

– General knowledge of condition codes 44 and W2 process

– General knowledge of local chargemaster build


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Revenue Integrity Chargemaster (Revenue Liaison or CDM Coordinator)

• To be effective in this role, the revenue liaison should have the following knowledge of, and ability to: – Local chargemaster build – Charging processes and linkages– Edits and regulations– Outpatient coding tool referral process– Condition codes 44 and W2 process – Ability to work well and collaborate

with other departments (case management, nursing)

– Communicate well verbally and in writing

– 2‐midnight rule guidelines– CPT codes– HCPCS codes – APCs– CDI and coding processes


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The Playbook Provides an Overview of Observation CDI Oversight and Staffing

• The site will need to outline who has lead responsibility for observation CDI– Recommend reporting to inpatient CDI director – Other options include reporting to director of outpatient CDI or other RHM director designee

• Staffing – the initiatives selected for observation CDI will determine the staffing resources and skill sets needed– Utilize the skill set list to identify local subject matter experts – Existing staff may possess the skills needed and be able to assume additional tasks and responsibilities associated with the initiatives selected

– Additional training or staffing resources may be needed


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Observation CDI Technology and Tools

• Outpatient coding system tool that surfaces NCD/LCD edits at the time of coding for coder resolution or for referral to the servicing department for follow‐up and resolution

• Claim adjudicator and charge capture system

Guidelines/tools in place that support outpatient CDI:• Observation charging guideline and job aids• Infusion and injection documentation and charging guideline and job aids• ED E/M facility charging guidelines and tools


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Observation Reports

• Outpatient Code Editor (OCE)/National Correct Coding Initiative (NCCI) edit reports

• APC error reports• Facility E/M distribution reports • CPT code and no charge report• Missing revenue code report


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Documenting Workflow and Interdisciplinary Collaboration

• It is recommended that the sites document the processes they will follow for the initiatives identified

• It is important to include how observation CDI will collaborate with case management, utilization management, and providers

• Sites will need to determine how they will track the reviews and query activity that may result– The inpatient CDI program in place can track and monitor observation CDI reviews and query activity – system build is required

– Reports in the CDI tool keep IP and OP CDI activity separate


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Establishing Observation CDI Metrics

• Denial data – improvement in reduction of denials• Review rates – how many observation patients that were subsequently

admitted had a CDI review and/or query• Query activity – rates, responses, and agrees (i.e., how many queries were

generated based on observation patients, how many responses were received, and how many agreed with the query)

• Revenue impact – impact of queries (e.g., impact of documentation on conversion to inpatient status, denial reduction impact, see list of areas of focus above for additional impacts to track)

• Outpatient NCD/LCD edits – addressed and revenue impacted via outpatient coding tool

• Track lost charges – tracked via claim adjudicator and charge capture system tool


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Existing Systems/Tools Available

• Our coding software offers an outpatient referral process to send claims to ancillary departments for various corrections pre‐bill to send out clean claims and eliminate rework

• Enterprisewide claims adjudicator and charge capture system used at the corporate office and can be used at the facility level

• Our inpatient CDI software application can be configured to review observation and other outpatient cases to allow for tracking of CDI work as well as reporting of metrics

• The playbook provides instructions on how to obtain access and training on each of the tools


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Data in the Claims Adjudicator and Charge Capture System

• The revenue integrity team at the corporate office uses this tool to identify potential areas of opportunity for the RHMs

• Scrubbed claims data, detailed charge information, and remittance advice data is loaded into the tool on a daily basis

• A series of edits is run for all the sites looking for missed code combinations, incorrect units of service, etc.

• Corporate office or local site resources then review the medical record to verify coding/charging around the edit to identify if charges or codes were missed

• Any missing information is added to the accounts and they are rebilled


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One Site’s Journey


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Background

• Engaged an outside consulting firm to review outpatient revenue opportunities

• Initial data collection and review took several months (Mar–May 2015)– On‐site shadowing of clinical areas at all sites– Deep dive documentation review– Pricing opportunities through managed care contract reviews (lesser of)– Interviews and process reviews with various areas of revenue cycle– Retrospective review of billing data through charge capture tool

• The result was the identification of key areas with greatest potential impact, thus creating the OP CDI Initiative


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Key Focus Areas

• Surgery case levels – updated procedure level assignments• Emergency E/M visit levels – focused on improving nursing documentation of

assessments and procedures• Infusions and injections – developed daily worksheet and weekly summary to

identify missing stop times• Observation CDI – focused on cases with greater than a 24‐hour length of stay

and worked with physician to get more diagnosis‐specific language with goal of converting patient to inpatient stay or shorten observation stay

• Direct admit to observation – clarified documentation of direct admit status and worked with revenue coordinators to clarify what is allowable to be charged as a direct admit observation


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Track Revenue Optimization Net Revenue Impact

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$0

$5,000

$10,000

$15,000

$20,000

$25,000

$30,000

$35,000

Year 1 Year 2 Year 3

$6.6M $6.6M $6.6M

$16.2M $16.2M

$7.9M

Net Patient Reven

ue(in

000

s)

FY18

FY17

FY16 (Jan ‐Jun)

FY 18 Cumulative Impact:

$30.7M

$22.8M

Outpatient CDI Initiative


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Challenges and Next Steps


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Challenges in Outpatient CDI Change Just as Quickly

• Sites in varying phases of implementation • Lack of resources to provide the level of support as inpatient CDI has• Sites that have not started outpatient CDI programs are at various stages of

readiness to begin this task • Some sites overwhelmed at the size and scale of outpatient CDI (just don’t

know where to start)• Many of the CFOs want to know what the potential benefit to them is and are

not supporting moving forward until that information is available• The absence of industry best practices such as outpatient CDI standards and

metrics are a challenge• Sites have not fully embraced the system tools that have been available to them

for many years


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Any Work in Outpatient CDI Is Better Than No Work

• Our outpatient strategy and tools may not be perfect, and we will have to be flexible and agile in order to provide support to our sites

• We will need to continue to educate all levels of the organization on what outpatient CDI is and how it differs from Inpatient CDI

• We plan to start small and continue to build and learn from each other –sharing best practices and early successes

• An eye toward continuous process improvement will be required if we are to be successful in this endeavor


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References

• Butler, M. (2017). CDI programs expanding outside the hospital. Journal of AHIMA, 88(7), 15–17.

• CDI should follow move to outpatient services, plays role with HCCs. (2017). Report on Medicare Compliance, 26(30), 6–7. Retrieved August 28, 2017.

• ACDIS. (2016). White paper: Outpatient clinical documentation improvement (CDI): An introduction. Brentwood, TN: HCPro.

• Yuen, A. (2016). Define outpatient CDI nuances. CDI Journal, 10(2).• Yuen, A., & Knauss, P. (2017). First steps in outpatient CDI: Tips for building a program. Brentwood, TN: HCPro.


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Thank you. Questions?

jmoreau@trinity‐health.orgAndrea.Eastwood@trinity‐health.org

In order to receive your continuing education certificate(s) for this program, you must complete the online evaluation. The link can be found in the continuing education section of the program guide.


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Appendix


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Executive Champion Role Expectations

• The executive sponsor is the local site executive designated as the program champion.

• Key responsibilities include:– Provides executive guidance and keeps program in alignment with organization’s strategic mission, vision, and budget targets

– Ensures program has the resources and tools in place to be successful– Assists with multidisciplinary collaboration across departments and with the medical staff

– Ensures program success by removing barriers


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Outpatient CDI Director Role Expectations

• Accountability for outpatient CDI program • Accountable to identify outpatient CDI program priorities and areas of focus • Day‐to‐day intense oversight of the outpatient CDI program • Ability to collaborate with all levels of the organization and with the medical staff• Ability to manage multiple priorities • May function as the outpatient CDI oversight committee leader• Provide ongoing updates on outpatient CDI program performance to the outpatient

CDI oversight committee and executive leadership • Ensures metrics and monitoring process are in place to ensure outpatient CDI program

success• Perform staff evaluations • Strong organizational, analytical, writing, and interpersonal skills • Knowledge of CDI and coding


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Outpatient CDI Oversight Committee Structure Outline

• Outpatient clinical documentation improvement (CDI) program oversight committee recommended structure and draft charter– It is strongly recommended that outpatient CDI programs have in place a forum for the key

executive stakeholders and stakeholder departments and roles meet on a regular basis to report outpatient CDI program metrics, share program successes and issues, as well as remove barriers in support of the outpatient CDI program

• Goal and objectives of outpatient CDI program oversight committee: – Provide framework for outpatient CDI program in relation to site's strategic plan, vision,

and initiatives– Provide an oversight forum for executive leadership to monitor outpatient CDI program

activities– Review outpatient CDI program metrics, celebrate successes, and develop action plans as

appropriate– Ensure resources are in place to support the outpatient CDI program


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Outpatient CDI Oversight Committee Structure Outline (cont.)

Membership would include the executive sponsor, director of outpatient CDI, and key stakeholders across all departments included in the outpatient CDI program's areas of focus. • Recommended membership:

– Executive champion – CFO/COO – CMO– CNO (if applicable for areas of focus)– CDI physician champion if one is designated for outpatient CDI– Outpatient CDI director/manager/lead– HIM director/coding manager– Key stakeholder department directors/managers/leads– Revenue and charge capture directors/managers/leads


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Outpatient CDI Oversight Committee Structure Outline (cont.)

• Schedule: – It is recommended the outpatient CDI program oversight committee meet weekly during

an initial implementation. Monthly or quarterly meetings are appropriate after initial implementation.

– Alternative approach to outpatient CDI program oversight committee meetings would be to include an outpatient CDI program report as part of an existing executive leadership team agenda on a monthly or quarterly basis in lieu of a creating a separate committee.

• Suggested agenda or report items:– Update on current initiatives (underway and planned)– Review of outpatient CDI metrics being tracked – Review outpatient CDI financial benefit – Discussion and resolution of challenges and barriers


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