Coding: Inpatient or Outpatient, Risks (and Benefits) Are Increasing E&M, DRG, APC, Risk Adjusted, CDI, and Hospice … It All Matters

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Ensure accurate coding and billing by reviewing the coding and compliance policies woven into a health system’s revenue cycle.

Because coding can be confusing and laborious it can often be overlooked and potentially not recognized as part of the revenue cycle process. Now more than ever before, coding reviews are an important component of a health system’s overall "value”-based payment continuum, due to continued scrutiny by Medicare/Medicaid and commercial payers. Health system executives are tasked with optimizing performance of and maximizing efficiency of the coding stage in the revenue cycle. Accurate coding leads to clean claims, which results in prompt reimbursement, and that’s why coding has a direct impact on the bottom line.

Coding is a moving target for many providers. Omnipresent and at times inconvenient and confusing, the ever-changing demands coupled with the risk of inaccuracy constantly challenges providers. With severity of care levels and clinical outcomes increasingly tied to “value,” reimbursements will inextricably link with accurate disease-state coding and documentation. Also, with provider compensation woven tightly to provider production (with emerging compensation models embracing quality and efficiency components, as well), accurate coding confirms both proper reimbursement to the system and accurate compensation for those providers on productivity models.

Educating providers mitigates downside risk to health systems and hospitals and offers leadership (the C-suite along with the physician executive team) the prophylactic of ongoing monitoring ensuring that the administrative/physician partnerships are cemented in a compliant manner.

Coding Compliance

A successful coding review and compliance plan should be crafted to define the hospital or health system’s investment and belief in coding compliance. A memorialization of the processes and procedures undertaken in a coding review enshrines that all constituents clearly understand the goals, objectives, and expectations of the hospital/system. Coding/compliance plans cannot be one-dimensional relying solely on documentation of services or an information technology solution. For instance, in a vacuum a provider can “pass” a coding assessment with proper documentation which generates work relative value units (wRVU). However, sometimes that productivity can be overly, and erroneously, robust given clinic hours, patient facing time, provider schedules, etc. Since most employed providers have a component of their compensation driven, at least in part, from a wRVU model, ensuring precise claim level of billing (e.g. a level 3 versus a level 5) offers physicians and health system leadership peace in the knowledge that claims, charges, and subsequent revenue are accurate.

Additionally, until block chain, “machine learning,” and other IT initiatives like artificial intelligence (AI) have firmly taken hold to “solve” coding and compliance issues, human-intervention will be required to certify that coding documentation aligns with patient facing time, required coding elements, and charting. EHRs can be dangerous when a user simply hap-hazardly “carries forward” a note which can offer a false sense of accuracy. Providers (physicians and APPs) must fully understand the rules and regulations of coding, especially in the critical nature of pay for value initiatives that are evolving over time. Additionally, and tangentially, carrying notes forward has potential med/mal exposure. All of that said, accurate coding is essential relative to severity of disease state, etc.

A Coding and Compliance Program - The "3 F's"


Delineate a program of ongoing review and analysis. It should have well-defined expectations. The program should be structured with defined timelines, be diligent, and guarantee random sampling and a rotating sequence of providers (depending on group size) for review. In program development “acceptable” parameters should be constructed indicating varying rates of post-review monitoring and education. The program should be “owned” by a staff member (with backup) to ensure it is perpetual and robust.


After reviews are performed, an expedient and concise feedback loop should be deployed displaying to providers deficiencies and providing education. For instance, if a provider “fails” 80% of his or her coding reviews for accuracy, he or she should be placed on a more frequent review process (every quarter?) as defined in the compliance plan to document a remediation process and catalogue improvement in accuracy.

The feedback loop should contain educational opportunities that celebrate successes and elucidate challenges. Providers should be counseled and offered “real time” assistance if coding issues or questions arise during the day.


The coding review should carry with it a robust follow-up plan ensuring that team members (from front desk to providers) understand that the plan is deployed and in force infusing into the culture a sense that the system or hospital takes, and will continue to take, coding compliance seriously. That is not to say that staff members should know that Dr. X failed his or her coding review. Instead, the message to staff should be that the system views coding compliance as a system-wide obligation and focus.

Stout’s coding/compliance leadership ties coding together with one point of contact to manage all aspects of review and education. Our seamless coding and compliance team delivers a variety of solutions based on client need. Stout associates manage outpatient, “pro fee” evaluation and management (E&M) and risk adjusted coding assessments and education, while deftly handling Ambulatory Payment Classification (APC), Diagnosis Resource Group (DRG), and Clinical Documentation Improvement (CDI) coding initiatives for inpatient coding. Additionally, we are adept at hospice and home care coding analyses. Our “borderless” approach empowers our team to rapidly address client needs by removing artificial “silos” that inhibit fluidity on multi-faceted projects running between health system, inpatient work and ambulatory reviews. Stout associates understand the congruency of in and outpatient facilities and can deliver reviews and offer a coding/compliance partner.

* To read more about Stout’s experience and how we provided a 15 to 1 return on a client’s initial investment by helping them improve on their revenuecycle, download our case study now.

Physician Compensation Value-Based Care Initiatives Bring Disruption

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Physician Executives: Are You Utilizing Their Talent?

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It is vital to anticipate how revenue cycle reports will be viewed across the organization.

If you are a hospital or health system with disengaged physicians, you are missing the boat (and probably bumping along, operationally and financially). Sound physician executive leadership empowers health systems to deploy curative operational solutions, offers providers input and a stake, and engages the physicians as valued partners versus cogs in the machine.

We recently performed a health system operational turnaround where the system was significantly subsidizing their employed physician network (e.g. losing money per physician). An undergirding issue (among many) was the lack of physician input into the organization. This reality left physicians fragmented, unappreciated, and undervalued. While there existed no discernable ill-will or animus, the physicians simply were not engaged nor asked to provide their input and insight. This chasm lent to chaotic differentiation from clinic to clinic amongst the system’s 16 clinic locations.

As a component of the overall structural rebuild we were engaged to perform, an immediate need was the creation of a physician advisory committee (PAC). As will be discussed, the implementation of a PAC had a direct impact on the health system’s revenue cycle. Within one year, system subsidies were reduced by 75% helping the system claw back toward profitability.

Setting the Table

In the instant situation, the health system was hemorrhaging cash. An operational assessment was performed on each clinic site. As part of the post-assessment implementation and rebuild, a PAC was created. Our team suggested that, out of the gate (and at least as a Band Aid) the system define and immediately select, even if temporarily, physicians who exhibited tendencies toward engagement. The key was identifying physicians engaged in affecting change but who, to this point, had not been asked to. (While building the PAC quickly is not ideal, this build drove the hospital system to immediately draw from the talented physicians who sought to make a difference).

Standards, rules, and measures were delineated vis-à-vis tenure, mission, duties, etc. Each physician on the committee was known to be an “invested” partner who, to this point, had had no voice.

In the newly born committee, the physicians:

  • provided an avenue for physician input and enhanced bi-directional communication
  • provided a litmus for possible changes (e.g. comp plan redesign)
  • created quality initiatives
  • offered peer review and guidance
  • offered emotional buy-in and intellectual contributions
  • became valued partners
  • established key operational standards throughout the physician network
  • advised/consented on issues (the executive office maintained the final say)
  • had meetings that were agenda driven, and
  • assisted with electronic health record (EHR) optimization

While many of these items can be tackled by the C-suite, the reality is that most folks in the administrative offices don’t practice medicine and it is certainly easier to hear a message from a peer who lives the life you lead versus one who has not walked in your shoes.

Whether a network is large or small, some form of physician committee is advised and models are malleable and scalable; there is no one right answer. Two rudimentary (and simple) examples follow.

Figure 1: Small Health System

In a small system, as with the client referenced earlier (75 physicians), the PAC should have a limited number of participants (prorata specialty representation) and a well-defined scope of authority. In this case, the PAC might be constructed of 6 physicians of differing specialties. (In our turnaround situation, due to the urgency of time, the PAC was entirely staffed by internal medicine physicians and the size of the system and specialty medical staff rendered that sound, at least in the emergent near-term).

The PAC receives input and provides feedback to the employed physicians. And, if this is a clinically integrated model (CIM) with outside community physicians involved, they may be included to provide a consultative input role that offers thoughts apropos of care and quality (e.g. population health initiatives, etc.). The PAC then provides input to some sort of nimble (e.g. “small” in size) Executive Committee which may include representation from the PAC, the CEO, COO, CMO, CTO, etc., to work on and resolve the issues.

The feedback then flows back through to clinicians via the PAC.

Figure 2: Large Health System, with diverse subspecialty representation

In a larger health/hospital system, the PAC might have an expanded multi-specialty representation and may be larger in membership/construct. The system may have one physician representing each specialty who serves as a conduit for his or her specialty constituency. For instance, a system might have a cardiologist who is the lead for the other cardiologists to ensure that their specialty-specific needs are addressed. The cardiology lead might then serve on the PAC or report up the concerns of the “cardiology section.” These issues would then be addressed by the PAC. (Remember, this construct does not limit or hinder provider access to the administrative offices and/or the CEO. It simply provides a structured method to obtain and deploy input from clinicians.)

Ideally, representation as either the “section lead” or on the PAC should be voted on by peers. This engenders greater support and commitment from other physicians. That said, the “section lead” should be a leader, not an antagonist. A representative with an axe to grind for some 10-year-old grievance (real or imagined) does no service to the organization and is counterproductive. Only honest brokers out for the betterment of the organization and their constituents need apply.

This model is scalable based on the number of constituencies. As with the small group model, a well-defined scope of authority should be deployed. In this case, the PAC might be constructed of physicians of differing specialties due to the diversity of specialization/sub-specialization within the system. The PAC receives input and provides feedback to the employed physicians. And, as with the small system model, if this is a clinically integrated model (CIM) with outside community physicians involved, they may be included to provide a consultative input role that offers thoughts on care, quality, and continuity of care (e.g. population health initiatives, etc.) throughout the community.

Will creation of a PAC cure all of a health system’s financial and operational woes? Certainly not. But your valued partners can go a long way to flattening the curve and remedying structural deficiencies.

* To read more about Stout’s experience and how we provided a 15 to 1 return on a client’s initial investment by helping them improve on their revenuecycle, download our case study now.

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Physician Compensation Value-Based Care Initiatives Bring Disruption

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Physician Compensation – Value-Based Care Initiatives Bring Disruption

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Physician compensation arrangements have changed under constant and fluctuating pressure from the dynamism of the healthcare landscape.

Physician compensation arrangements have evolved during the last two-plus decades. Not only have they changed, but they’ve done so under constant and fluctuating pressure brought on by the dynamism of the healthcare landscape.

In the 1990s, as hospitals gobbled up physician practices with an eye toward managed care, the hospitals generally offered robust salary guarantees. As might be expected, broadly speaking, the health systems began bleeding money from their employed ventures. Health system employment transitioned many of the headaches of private practice management from the physicians to the hospitals and, in many cases, offered providers rich deals with limited downside. (Of course, trading day-to-day management of a practice for employment is a give/get proposition.)

Where once physicians managed their practices to ensure “below the line” profitability (which ostensibly passed through to the shareholders), employment models mitigated the need for physicians to run their practices in a cost-effective manner. Concurrently, these employment models removed worries about things, such as HIPAA, information technology (IT), staffing, medical malpractice costs, rent expense, and revenue cycle (RC) management. Those management headaches were transferred to the hospitals. In many cases, provider production was static or declined theoretically because the physicians were guaranteed incomes regardless of cost drivers.

In the examples below we take a high-level look at compensation shifts for the last two decades.

Figure 1.

1990s Physician Compensation

First, the caveat to this article is that it is, by design, overly simplistic (but directionally accurate). It is built to use bite-sized graphics to display mathematical machinations and convey those to the reader. Actual compensation plan design is complicated with many moving parts.

Preamble aside, as evidenced in Figure 1, let’s assume that Dr. X’s private practice generated $250,000 in revenue (cash accounting). Expenses for the same period were $100,000. That left $150,000 in gross revenue. In the private practice setting, money not spent running the practice drops to the bottom line and the shareholders. In this case, Dr. X, as noted in the Private Practice column above, had gross revenues of $150,000, so he paid himself a salary of $150,000. (If he had shaved $50,000 in expenses, he otherwise may have paid himself an additional $50,000 or a salary of $200,000.)

Now let's say that Dr. X has grown disenchanted with day-to-day management of running a medical practice. He simply wants to practice medicine. Fast forward to when Dr. X becomes employed by Hospital Y. We’ll suggest that Dr. X is an internal medicine provider and Hospital Y is growing its internal medicine base. The hospital guarantees that Dr. X will make $300,000 per year. However, as indicated under the Employment column in Figure 1, Dr. X generates no more revenue and his expenses are static. Removing his guaranteed compensation leaves the system $150,000 in the red for Dr. X (otherwise known as “subsidizing” the physician).

After rivers of red ink, in the late '90s, many systems divested medical clinics, creating a period of detente. However, in the 2000s, the acquisition game began anew. Medicare’s reimbursement cuts to many specialties on in-office procedures (such as imaging) essentially flipped the economics of the medical practices. For those practices that were greatly impacted (with high Medicare populations) and that may have been poorly managed (e.g. inflated expenses), the loss of revenue shrinking the delta of profitability drove many providers to the relative protection of the health systems.

2000s and the wRVU model

In the 2000s, systems that acquired physicians took a decidedly different tack toward the compensation conundrum. In lieu of a big guarantee, health systems began to reward physicians for the work performed. While not perfect, the work relative value unit (wRVU) compensation models provided a means of objectively rewarding providers for “working.” That simply translated into more work, more pay; less work, less pay. This offered systems some downside protection for reduced physician productivity. (Concomitant with the wRVU productivity model are inherent downsides.)

Many newly crafted compensation plans, whether stepped/tiered threshold models or cash/wRVU payments, were deployed.

Figure 2

2000s Physician Compensation

Physician plans began compensating, either in whole or part, based on the individual provider’s productivity to stimulate providers with financial upside, should they hit productivity goals. It should be noted that these models generally do not account for revenues collected per wRVU, purely the production side. For instance, in Figure 2, if we pay Dr. X $25/wRVU and we only collect $20/wRVU, we are decidedly underwater from the get-go exclusive of our cost structure within the health system. It is incumbent on the system to tactically manage its revenue cycle to ensure maximum collections of money due the system.

Figure 3

2000s Physician Compensation

In Figure 3, Dr. X is generating $750,000. The cost to run his practice is $250,000. (Exclude accrual accounting from the equation – for example’s sake, this is collected money.) Dr. X is guaranteed a small base ($75,000) and is paid $25/wRVU. Generating 10,000 wRVUs, Dr. X has added another $250,000 to his compensation for total physician compensation of $325,000. Reducing the gross revenue by the provider compensation leaves a profit of $175,000 (most systems “subsidize” employed providers).

Many of these models, in some form or another, exist today, holdovers that are fairly easy to understand and implement. Some private practices have even deployed these models in an attempt to motivate providers and enable them to choose their workload while clearly understanding how that might impact them.

Enter the Value Era

Many health systems and hospitals are contemplating changing their compensation structures, disrupting current paradigms regarding physician pay by embedding components addressing rules from Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) and its associated component pieces of the new Merit Based Incentive Payments System (MIPS) and alternative payment models (APMs) into compensation plan design.

Systems with employed physicians who are not knee-deep in MIPS or APMs begin with one foot in hole. However, forward-thinking systems are beginning to evaluate how to incent physicians, marrying behavior with quality and efficiency as well as production.

As “pay for value” continues to evolve, compensation models must necessarily change to consider the value of care delivery. This creates a fine balance of quality care delivery while understanding that patient volume loads (and compensating for the same) may not soon recede. As these compensation plans evolve, systems must make sure that plans pass fair market value (FMV) review to ensure that the system is not overpaying the provider, which may draw the ire of the federal government.

We stipulate that this is not a cut-and-dried situation. This is a hypothetical example delineating the modus of compensation plan design, in broad strokes. Of course, systems will continue to reward for volume but also place a measurable value on quality and efficiency, driving the compensation to realize the value care models. That is, physicians will receive a component piece of their compensation based on care delivery, as evidenced in Figure 4.

Figure 4

Physician Compensation Incentive Package

As noted, this exercise isn’t intended to indicate how the system is making less money in Figure 4 than Figure 2 (as the data are fictive). It is simply a graphic to offer an examination of how physician compensation is being contemplated and evolving.

Using our Dr. X example, Hospital Y is deep into MIPS and has determined that its efforts require physician input into quality improvement. In Figure 4, Dr. X retains his nominal base pay and his wRVU production compensation that he had established in Figure 2. Additionally, the system crafted an “efficiency goal” defined as aiding in the reduction of 5% of controllable costs, which would add $25,000 to Dr. X’s compensation if he meets all of the requirements. The system also created a “quality” component of four disease states (ostensibly all valued at $10,000 each) for another $40,000 in potential compensation. These pieces must be measurable and “valued” and cannot be subjective in nature. As an aside, we advocate for a strong physician advisory committee (PAC). A PAC can advise and consent on the development of compensation programs and can assist the health system in determining clinical aspects of care delivery that can be managed and measured to improve quality and value outcomes.

Combining Dr. X’s incentives, we see that he generated $315,000 in incentives to tie in to his base of $75,000. Presuming that his gross revenue (the system is collecting $75/wRVU) is $750,000, removing expenses and MD compensation, the system realizes a $110,000 profit on Dr. X. (Again, as noted in the “2000s” example, most systems subsidize their physician practices/clinics.) The key, too, is ensuring that the “at risk” money (e.g. incentives) is priced at FMV rates and is robust enough to positively impact the physician’s behavior (e.g. production, an eye toward quality and efficiency, etc.)

Realizing the established efficiency and quality goals divined by the health system (with physician executive input) assists the system in moving forward with its goals to meet (or exceed) MIPS goals. The system correlates its efficiency and quality components by specialty to align with MIPS, ensuring that it receives the increased reimbursements two years hence (e.g. 2017 data impacts reimbursements for 2019, 2018 data impacts reimbursements for 2020, and so on).

As evidenced in Figure 5, most of Dr. X’s compensation is currently driven by his production. But that may shift as care value is measured, monitored, reported, and reimbursements are more closely aligned with quality of care. The crux of evolving compensation models revolves around the idea that compensation and quality will be woven into a tight tapestry where, at some point, there may exist a shift of a greater level of compensation from production to quality.

Figure 5

Compensation Percentage Allocation

Compensation plans must be carefully built with diligence then tested for FMV considerations. The models within a health system should be as consistent as possible so that there is little variation among system employees. This also renders compensation plans easier to manage.

As with most things in healthcare, there is no one right answer. Even in provider compensation, some things are local.

* To read more about Stout’s experience and how we provided a 15 to 1 return on a client’s initial investment by helping them improve on their revenuecycle, download our case study now.

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