When is Documentation Enough? Getting to the MEAT of HCCs


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
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About the Author

Rose Dunn
Rose Dunn is the Chief Operating Officer at First Class Solutions, Inc., a healthcare information management leader since 1988. Rose is the author of “The Revenue Integrity Manager’s Guidebook” available from the National Association of Healthcare Revenue Integrity and other books on Coding Management and Auditing from HCPro. She engaged herself in ICD-10 more than 10 years before it was implemented. She is assisting Libman Education in the development of an HCC educational program. Rose holds a BS and MBA from Saint Louis University.

8 thoughts on “When is Documentation Enough? Getting to the MEAT of HCCs

  1. Alicia Stahl - October 30, 2019 at 3:17 pm

    I am an IP CDI but find this to be very interesting. I often query for HCCs and do not know if all 4 MEAT criteria are met when I do so (something I’ll definitely keep in mind going forward). Given we operate in an EMR and the conditions are listed in a Problem List that displays for the OP provider (PCP) to address or work off of, do you see the IP CDI needing to be cognizant of this as well? I am also curious if there are specific HCC’s that these auditors are targeting as they often do, like one’s that really should meet all 4 criteria (chronic chf for example)? Thank you for bringing this to light!

  2. Christine Irwin - October 30, 2019 at 3:30 pm


  3. Andrea Rubinowitz - October 30, 2019 at 3:30 pm

    Wondering if you could help with this question – the AHA coding guidelines for outpatient encounters Section IV. – Diagnostic Coding and Reporting Guidelines for Outpatient Services specially – the guideline below
    J .Code all documented conditions that coexist at the time of the encounter/visit, and require or affect patient care treatment or management.

    How do you balance the need for hospital outpatient diagnosis assignment with this rule and medical necessity, denials versus the HCC concept directed Medicare Advantage payer reimbursement system?

    We have coders that do both Hospital OUPT and professional diagnosis code assignments and we want a consistent message to our coders without incurring reroute and additional work.

  4. Angela Birch - October 30, 2019 at 3:31 pm

    Would the following from Section 3 of the ICD-10-CM Official Guidelines for Coding and Reporting apply to HCC coding? As this is listed as “or” rather than “and” statements I think this supports you only need at least one.

    “For reporting purposes the definition for “other diagnoses” is interpreted as additional conditions that affect patient care in terms of requiring:
    clinical evaluation; or
    therapeutic treatment; or
    diagnostic procedures; or
    extended length of hospital stay; or
    increased nursing care and/or monitoring.”

  5. Lisa Hart - October 30, 2019 at 3:36 pm

    Hi Rose,

    Can you explain why this methodology is being adopted when it is not coming from an authoritative coding resource? Is this just another way for payers to skirt around official coding guidelines to deny payment??

  6. Laura Rowell - October 30, 2019 at 3:52 pm

    HI Rose I have noticed in the current ama 2020 iCD-10-cm codebook that MEAT is not under appendix E: documentation requirements as it was in the prior year. Why has this been left out?

  7. Kristin Rodriguez - October 30, 2019 at 8:38 pm

    That seems excessive to me. Wonder if it’s because of the rash of generic statements like “continue to monitor” that don’t really show much support? We require just one element as proof something was done.

  8. Lisa Hart - November 8, 2019 at 7:11 pm

    To all that have left a reply, AHIMA is updating their Evolving Roles in CDI for Physician Practice. We plan (hopefully) to address the issue of M.E.A.T. as part of this brief. It is not a recognized documentation guideline published anywhere. Not in ICD-10, 95 or 97 guidelines.