by Rose T. Dunn, MBA, RHIA, CPA, CHPS, FACHE, FHFMA
As we all know, thorough and complete documentation is essential to support Hierarchical Condition Category (HCC) coding. But how do we know when the documentation is enough? I am seeing alarming reports of auditors rejecting HCC diagnoses based on what they are claiming is insufficient documentation applying a standard that is higher than what was required in the past.
While at the Revenue Integrity Summit this week, I had a nice conversation with a physician leader of a large practice in Florida. His practice is immersed in HCCs. He said he is experiencing rejected HCCs where the diagnosis documentation is not meeting ALL 4 elements of MEAT.
Our long-time standard for when to code a condition is if it meets one or more of the MEAT criteria: that is the condition is Measured or Monitored; Evaluated; Assessed or Addressed; and/or Treated. Examples include:
- Monitor – signs, symptoms, disease progression, disease regression
- Evaluate – test results, medication effectiveness, response to treatment
- Assess/Address – ordering tests, discussion, review records, counseling
- Treat – medications, therapies, other modalities
The payers that are denying the HCCs for this practice in Florida is requiring all of the elements to be met, not just one or more. This strikes me as an unnecessarily high standard and is a change from documentation and coding requirements of the past.
My advice to physician practices is that their CDI and coding staff work to ensure documentation is complete and demonstrates all four MEAT elements.
Let me ask a question of you: What is your experience? Are you seeing similarly aggressive denials based on this higher standard? Have you effectively challenged this new standard?
Until there is guidance and clarity of this topic, my bottom line for you is this: The more MEAT elements that are documented for a condition, the better.
Fundamentals of HCC Coding
Learn more from Rose! Go beyond just the diagnoses — really understand the methodology behind HCCs with the course “Fundamentals of HCC Coding.” Learn more here.