Clinical Documentation Matters

This may be a long stretch for many organizations.  But if you think about the minimal cost to an organization for paying a physician to serve on a board for clinical documentation planning, the benefits far outweigh the expenses.  If your organization has an interest in this type of venture, you will need to be explicit about the responsibilities of the physician advisors. The advisory board cannot be like every other committee that physicians may serve on in your hospital, since they are not paid for those activities. The physicians would have additional responsibilities.  Perhaps you can train them to be peer reviewers or trainers for physician CDI training. If you limit the advisory board member service time to six months or a year, not only would it potentially appeal more to the members, it would also give your organization the opportunity to intensively train several physicians a year in CDI principles. With the right planning, the right physician participants, and the right process, the results could prove to be mutually beneficial to the organization and to the physicians.  You should consult your compliance officer for specific guidance on how to create the advisory board and work with physicians compliantly.  There are certain Medicare anti-trust laws that prohibit hospitals from giving physicians anything of value that would appear to be an inducement to the physician for admitting patients to the hospital.  However, if the hospital is paying the physicians fair market value for actual work performed outside of normal hospital duties, this should not be a problem.  The activity should be overseen by your compliance team or your general counsel’s office.