Ensuring coding compliance through the OIG work plan

March 6th, 2018

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Note:  The following article synopsis was NOT provided by HCPro. It was created by Find-A-Code/innoviHealth.

Article Overview

This article discusses how healthcare organizations can use the OIG Work Plan to identify and manage coding compliance risk. It focuses on broad areas of documentation review and clinical validation in inpatient coding, bariatric surgery documentation, and rehabilitation-related diagnosis coding concerns, making it relevant to coders, CDI professionals, compliance officers, and HIM leaders.

Why This Topic Matters

The topics highlighted in the article reflect areas that may attract payer or government review and can affect claim integrity, reimbursement, and audit readiness. Understanding the scope of these compliance concerns helps organizations align documentation, coding practices, and internal policy review with external oversight priorities.

Article Sections

  1. Severe malnutrition

    This section addresses OIG scrutiny of inpatient malnutrition coding and the related need for facility-level clinical validation and documentation review. It also discusses broader ICD-10-CM compliance considerations tied to nutrition-related diagnoses and inpatient claim review.

  2. Bariatric (morbid obesity) surgery

    This section covers bariatric surgery documentation and coverage review concerns raised by the OIG. It outlines the general types of missing or insufficient documentation that can affect compliance and claim support.

  3. Rush University

    This section discusses an OIG report involving inpatient and outpatient billing concerns and related compliance risks. It also reviews rehabilitation coding and documentation issues that can affect case-mix classification and related review activity.

What You Will Learn

  • How the OIG Work Plan can signal coding compliance risk areas
  • What kinds of documentation and validation processes are emphasized for inpatient coding review
  • How bariatric surgery documentation is evaluated for coverage and compliance concerns
  • What rehabilitation coding and case-mix documentation issues are highlighted in compliance discussions
  • Why internal policies and workflows matter for supporting coded diagnoses and services

Who Should Read This

  • Certified coders
  • Clinical documentation integrity professionals
  • Compliance officers
  • HIM directors and managers
  • Revenue cycle leaders
  • Physicians and other documentating providers

Codes Discussed

  • ICD-10-CM: E40
  • ICD-10-CM: E43
  • ICD-10-CM: R00.0
  • ICD-10-CM: R99
  • ICD-10-CM: B20

Code Ranges Discussed

  • ICD-10-CM: E40–E43
  • ICD-10-CM: R00.0–R99

Modifiers Discussed

  • HCPCS Level II: -59

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