Health Information Management

News: Use OIG compliance tips for ICD-10 implementation

CDI Strategies, September 30, 2010

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Realizing that the go-live date won’t change, some facilities already have organization-wide ICD-10 implementation strategies in place. If your CDI program hasn’t yet been involved in ICD-10 discussions or if your facility hasn’t starting the planning process yet, consider incorporating elements of the Office of Inspector General’s (OIG) compliance guidance published in 1998 and 2005, regarding the importance of compliance training.

 The February 23, 1998 Federal Register, contains “The Compliance Program Guidance for Hospitals,” which states:
“Accurate coding depends upon the quality and completeness of the physician’s documentation. Therefore, the OIG believes that active staff physician participation in educational programs focusing on coding and documentation should be emphasized by the hospital.”
According to the OIG, hospitals that fail to adequately train and educate their staff members risk liability for the violation of healthcare fraud and abuse laws. The purpose of conducting a training and education program (whether the topic be compliance to anti-fraud laws or to ICD-10 implementation) is to ensure that each individual who functions on behalf of the hospital is fully capable of executing his or her role in compliance with rules, regulations, and other standards.
Based on this OIG guidance, customize the training for physicians based on their medical specialty, says Lolita M. Jones, RHIA, CCS, the principal of Lolita M. Jones Consulting Services in Fort Washington, MD. Start by generating reports to identify the most commonly reported diagnoses and procedures for each clinical department. For example, in the cardiology department, the ICD-10-CM/PSC training may focus on ICD-10-CM/PCS codes for:
  • Arteriosclerotic heart disease (ICD-10-CM diagnosis code I25.10)
  • Congestive heart failure (ICD-10-CM diagnosis codes I50.20–I50.9)
  • Cardiac arrhythmias (ICD-10-CM diagnosis codes I49.8 and R00.1)
  • Coronary bypass grafting (ICD-10-PCS procedure code table 021)
  • Cardiac catheterization (ICD-10-PCS code table 4A0)
  • Percutaneous transluminal angioplasty (ICD-10-PCS code table 027)
Map your top 25 ICD-9-CM principal diagnosis codes to the equivalent ICD-10-CM diagnosis codes, says Jones. Then audit inpatient cases to determine whether the records contain the necessary clinical information to support the ICD-10-CM equivalent of the assigned ICD-9-CM principal diagnosis code. Then use your findings to develop targeted ICD-10-CM/PCS training for physicians and other staff.
The CDI department can start conducting ICD-10 documentation audits this year, Jones says. Because comprehensive clinical documentation is beneficial regardless of which coding system currently used, it is not too soon to identify documentation strengths and weaknesses.
Editor’s note: Jones has developed a comprehensive ICD-10-CM/PCS Implementation Plan that she is teaching to hospitals and other providers. Her website is This article first appeared on Learn about the HCPro ICD-10 Basics Boot Camp which takes place in February in Texas and Nevada.

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