In the past, Clinical Documentation Specialists (CDS) would ask the provider if the patient had nutritional issues based on evidence in the history, physical exam findings and lab results. They would rely on history of weight loss, findings of emaciation and body wasting, BMI, protein, albumin to ask the provider if the patient had malnutrition and its severity. Hearsay, incorrect BMIs recorded because of faulty information, abnormal losses of protein from non-nutritional issues have led to incorrect documentation of malnutrition by providers. Medicare and RAC auditors have targeted inappropriate coding of malnutrition, in cases that it is the only CC or MCC.
Dietitians have bristled at the amount of malnutrition that has been recorded by providers inappropriately. Nutritional expertise truly resides in the dietitian’s domain. They can weed out weight loss hearsay, confirm accurate BMIs, and have more accurate determination of patients’ nutritional issues. But, they are not allowed to make the diagnosis because only the providers are licensed to make the diagnosis.
In 2012, parameters for evaluation and stratification of malnutrition by nutritionists were changed. BMI, protein and albumin parameters were taken out from the criteria in identifying malnutrition. Caloric intake, weight loss and duration, physical assessment findings of subcutaneous fat loss, muscle mass loss, fluid accumulation and reduced grip strength have become the primary parameters. Thus, making it even more difficult and confusing. Most providers are reluctant to call the diagnosis without the dietitian’s full assessment.
This leads to a catch-22 situation. The providers who are licensed to make the diagnosis do not feel they have the expertise. The dietitians who have the expertise are not allowed to make the diagnosis. The solution lies in a collaborative effort between the providers, dietitians, floor nurses, CDS, and even Wound Care RNs, PT and Pharmacy. All these folks have a stake in the capture of nutritional issues.
Since the dietitians are not able to cover all patients that are admitted to acute inpatient care, they need a good referral system from all the stakeholders. The floor nurse fills out a nutritional screening form for all patients admitted to inpatient care. CDS, Wound Care RNs, PT and Pharmacy can also refer patients directly to dietitians.
New policies and procedures for the dietitians have to be formulated to assess and make a determination of patients’ nutritional issues and their severity (mild, moderate, severe). They have to go through their own Nutrition committee and have the Medical Executive committee approve and authorize the initiative. Since physical assessments have not been traditionally part of their training, they need to be trained by Rehabilitation Medicine providers or PT to make the physical assessments (i.e., SQ fat loss, muscle mass loss, fluid accumulation, reduced grip strength).
It takes time for new policies and procedures to be approved. An interim agreement for dietitian referral needs to be established. Otherwise, some dietitians may not be willing to go outside their regular scope of work and comfort level. Gray areas can be resolved by full dietary team consultation.
All of the above can only be undertaken with the cooperation of the dietary department. A preliminary meeting with the clinical manager of the dietary department would be the first step, which leads to a discussion of the need for their cooperation in starting an initiative. Showing how nutritional issues affect clinical outcomes as well as its financial impact may help convince the need for such an undertaking. Administration support for this initiative is critical.