The Cornerstone of Compliance: Your Workflow

In my last column, 2018 Checklist: Organizing Your Department for the New Year (January 2018), we discussed the value of checklists and how they can be created and used as written guides to help your team meet key steps in compliance. In this column, we will look at the value of developing and managing your clinical documentation workflow. With so many clinical and regulatory requirements, it is important to take a “wound care workflow time-out” to ensure your documentation is up to date and compliant with the ever-changing rules.

Designing clinical and operational workflows requires review and customization of current clinical and documentation practices for an efficient outcome. Current practices include the operational processes for registration, coding, medical records, and billing as well as the cognitive workflow by the clinicians. Producing the right mix of operational oversight and clinical experience, grounded with a solid documentation system, will produce efficient business practices within your electronic medical record and optimal patient flow and care.

Investing time and expertise in developing appropriate workflows is imperative, as well as a team effort. When developing workflows, it is important to consider how the workflow design will affect documentation through managing messages, scheduling patients, checking in and rooming patients, conducting the patient examination, managing medications, and discharging the patient.¹ This investment yields patient satisfaction, improved department processes to increase efficiency, reduction of errors, and improved outcomes, as well as patient and staff safety.

Let’s take a look at the Merit-based Incentive Payment System (MIPS) and how the MIPS requirements impact your cognitive and clinical documentation workflows and ultimately auditing of the documentation. The electronic medical record workflows must be flexible enough to capture significant amounts of regulatory data for Advancing Care Information, Improvement Activities, and Quality. These reportable data serve as the basis for MIPS reporting. Therefore, it is important to understand the MIPS requirements, how these requirements impact documentation during patient-facing data collection on existing forms, and how the workflows guide policy for proper documentation and reporting processes.

Equally important to collecting MIPS documentation is understanding and proactively collecting the documentation necessary for a MIPS Audit. Let’s review the potential for a Centers for Medicare & Medicaid Services (CMS) audit post–MIPS documentation and reporting. As stated in the Department of Health and Human Services’ review of CMS’s management of the Quality Payment Program: