Outpatient CDI Impacts New Payment Models

A Pittsburgh-based MD weighs in on an emerging area of focus in the healthcare industry.

EDITOR’S NOTE: The following are remarks made by the author during a recent broadcast of Talk Ten Tuesdays.

Today I would like to focus on outpatient clinical documentation improvement (CDI), often referred to as the lowly stepchild of inpatient CDI efforts. 

Personally, I feel it (outpatient CDI) can take over the spotlight from inpatient CDI, as it encompasses both the inpatient and outpatient world.  Outpatient CDI programs are directed primarily by primary care providers, which are increasingly getting involved in shared savings agreements, Advanced Payment Programs (APPs), and the Merit-Based Incentive Payment System (MIPS). However, many specialists are asking to be involved as well.  

One of the biggest differences between inpatient and outpatient CDI is that in the former arena, providers actually care about what you are teaching them. Providers who are engaged in risk-bearing contracts know that it is up to them to document and code the diagnoses that are relevant to the risk model. What a provider documents and codes will determine how successful they are in these risk-bearing contracts. But how can a provider remember all the things they need to document and code? 

At the University of Pittsburgh Medical Center (UPMC), we have risk-bearing contracts for Medicare Advantage, Medicaid, and the Patient Protection and Affordable Care Act (PPACA) plans, in addition to MIPS. It is impossible for any provider to know which diagnoses are relevant for each model, or to know if the diagnosis has been captured for the calendar year.  

In addition, approximately 80 percent of our outpatient visits are coded by the provider, not a coder. As we all know, providers, especially physicians, are not taught coding and documentation rules in their training. We are trying to remedy that at UPMC, but it would be impossible to rely on providers to remember the relevant diagnoses for each risk-based model, and to ensure that they get on a claim.  

One way to address this is to give the provider a list of diagnoses that have been coded in the past for their patient. This is helpful, but many providers find it annoying to have to deal with paper or electronic alerts for diagnoses that may or may not be relevant for the current visit. 

Most providers get 15-20 minutes to spend with a patient, and we have heard loud and clear that they want an easy-to-use tool to help them document and code their visits appropriately. In response to this, we have created a tool to help our providers. The tool will be embedded in our outpatient electronic medical record (EMR), and when a provider opens the encounter, it will reveal the relevant diagnoses for their patient, show them where the diagnoses came from, and make it easy to document the Monitor, Evaluate, Assess, and/or Treat (MEAT) and put the diagnosis on the claim. We will be going live with this system in the next eight weeks. 

Even with such a tool, it is always important to educate your providers about the risk models. For our doctors, the Centers for Medicare & Medicaid Services-Hierarchical Condition Category (CMS-HCC) model is the most common risk model used. 

I would like to end with an outpatient CDI tip for your providers: CKD 3 is once again an HCC! It has a very small weight, but considering how common CKD 3 is in our population, this is a gift to many providers. 

Facebook
Twitter
LinkedIn

Adele L. Towers, MD, MPH, FACP

Dr. Towers is the senior clinical advisor for UPMC Enterprises. She is directly involved in the development of healthcare-related technology, with emphasis on use of Natural Language Processing (NLP) for risk adjustment coding and use of clinical analytics to optimize clinical performance. Prior to this role, she has served as the medical director for health information management (HIM) at UPMC, with responsibility for clinical documentation improvement as well as inpatient coding denials and appeals.

Related Stories

Can Any Physician Enter an Inpatient Order?

Can Any Physician Enter an Inpatient Order?

Let’s talk about the term “attending physician.”  The simplest definition is the physician primarily responsible for a hospitalized patient’s care.  While there may be many

Read More

Leave a Reply

Please log in to your account to comment on this article.

Featured Webcasts

Sepsis Sequencing in Focus: From Documentation to Defensible Coding

Sepsis sequencing continues to challenge even experienced coding and CDI professionals, with evolving guidelines, documentation gaps, and payer scrutiny driving denials and data inconsistencies. In this webcast, Payal Sinha, MBA, RHIA, CCDS, CDIP, CCS, CCS-P, CCDS-O, CRC, CRCR, provides clear guideline-based strategies to accurately code sepsis, severe sepsis, and septic shock, assign POA indicators, clarify the relationship between infection and organ dysfunction, and align documentation across teams. Attendees will gain practical tools to strengthen audit defensibility, improve first-pass accuracy, support appeal success, reduce denials, and ensure accurate quality reporting, empowering organizations to achieve consistent, compliant sepsis coding outcomes.

March 26, 2026
I022426_SQUARE

Fracture Care Coding: Reduce Denials Through Accurate Coding, Sequencing, and Modifier Use

Expert presenters Kathy Pride, RHIT, CPC, CCS-P, CPMA, and Brandi Russell, RHIA, CCS, COC, CPMA, break down complex fracture care coding rules, walk through correct modifier application (-25, -57, 54, 55), and clarify sequencing for initial and subsequent encounters. Attendees will gain the practical knowledge needed to submit clean claims, ensure compliance, and stay one step ahead of payer audits in 2026.

February 24, 2026
Mastering Principal Diagnosis: Coding Precision, Medical Necessity, and Quality Impact

Mastering Principal Diagnosis: Coding Precision, Medical Necessity, and Quality Impact

Accurately determining the principal diagnosis is critical for compliant billing, appropriate reimbursement, and valid quality reporting — yet it remains one of the most subjective and error-prone areas in inpatient coding. In this expert-led session, Cheryl Ericson, RN, MS, CCDS, CDIP, demystifies the complexities of principal diagnosis assignment, bridging the gap between coding rules and clinical reality. Learn how to strengthen your organization’s coding accuracy, reduce denials, and ensure your documentation supports true medical necessity.

December 3, 2025

Proactive Denial Management: Data-Driven Strategies to Prevent Revenue Loss

Denials continue to delay reimbursement, increase administrative burden, and threaten financial stability across healthcare organizations. This essential webcast tackles the root causes—rising payer scrutiny, fragmented workflows, inconsistent documentation, and underused analytics—and offers proven, data-driven strategies to prevent and overturn denials. Attendees will gain practical tools to strengthen documentation and coding accuracy, engage clinicians effectively, and leverage predictive analytics and AI to identify risks before they impact revenue. Through real-world case examples and actionable guidance, this session empowers coding, CDI, and revenue cycle professionals to shift from reactive appeals to proactive denial prevention and revenue protection.

November 25, 2025

Trending News

Featured Webcasts

Mastering MDM for Accurate Professional Fee Coding

In this timely session, Stacey Shillito, CDIP, CPMA, CCS, CCS-P, CPEDC, COPC, breaks down the complexities of Medical Decision Making (MDM) documentation so providers can confidently capture the true complexity of their care. Attendees will learn practical, efficient strategies to ensure documentation aligns with current E/M guidelines, supports accurate coding, and reduces audit risk, all without adding to charting time.

March 31, 2026

The PEPPER Returns – Risk and Opportunity at Your Fingertips

Join Ronald Hirsch, MD, FACP, CHCQM for The PEPPER Returns – Risk and Opportunity at Your Fingertips, a practical webcast that demystifies the PEPPER and shows you how to turn complex claims data into actionable insights. Dr. Hirsch will explain how to interpret key measures, identify compliance risks, uncover missed revenue opportunities, and understand new updates in the PEPPER, all to help your organization stay ahead of audits and use this powerful data proactively.

March 19, 2026

Top 10 Audit Targets for 2026-2027 for Hospitals & Physicians: Protect Your Revenue

Stay ahead of the 2026-2027 audit surge with “Top 10 Audit Targets for 2026-2027 for Hospitals & Physicians: Protect Your Revenue,” a high-impact webcast led by Michael Calahan, PA, MBA. This concise session gives hospitals and physicians clear insight into the most likely federal audit targets, such as E/M services, split/shared and critical care, observation and admissions, device credits, and Two-Midnight Rule changes, and shows how to tighten documentation, coding, and internal processes to reduce denials, recoupments, and penalties. Attendees walk away with practical best practices to protect revenue, strengthen compliance, and better prepare their teams for inevitable audits.

January 29, 2026

AI in Claims Auditing: Turning Compliance Risks into Defensible Systems

As AI reshapes healthcare compliance, the risk of biased outputs and opaque decision-making grows. This webcast, led by Frank Cohen, delivers a practical Four-Pillar Governance Framework—Transparency, Accountability, Fairness, and Explainability—to help you govern AI-driven claim auditing with confidence. Learn how to identify and mitigate bias, implement robust human oversight, and document defensible AI review processes that regulators and auditors will accept. Discover concrete remedies, from rotation protocols to uncertainty scoring, and actionable steps to evaluate vendors before contracts are signed. In a regulatory landscape that moves faster than ever, gain the tools to stay compliant, defend your processes, and reduce liability while maintaining operational effectiveness.

January 13, 2026

Trending News

Prepare for the 2025 CMS IPPS Final Rule with ICD10monitor’s IPPSPalooza! Click HERE to learn more

Get 15% OFF on all educational webcasts at ICD10monitor with code JULYFOURTH24 until July 4, 2024—start learning today!

CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 1 with code CYBER25

CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 2 with code CYBER24