The problems with the problem list are many, including invalid HCC assignment and compliance risks

The problem list. 


(I can’t bear to say, “it’s a problem,” because that’s almost as cliché as, “if it’s not documented, it’s not done.”)


But I went ahead and just said both. 


Anyway, the problem list is both of source of great information for coding and CDI specialists for query, while also simultaneously being a tremendous headache. Physicians often use it as a running thought exercise, resulting in a collection of possible or ruled out diagnoses. Conditions are often missing or left off the problem list, or irrelevant information collected there.


And physicians often fail to update it, which means old acute conditions are carried over from year to year, and sometimes picked up by misled HCC coders. This is a problem hospitals need to tackle, given the recent heightened scrutiny around HCC reporting, Medicare Advantage and compliance.


What to do?


In my OPINION (emphasis deliberate—my personal opinion only), cleaning up the problem list should fall under the auspices of CDI staff.


I know this brushes up closely to clinical care, and gets people uncomfortable. But we’ve got a provider burnout crisis in the country. We should be helping providers at every turn, up to and including removing diagnoses that should no longer be on the problem list, and keeping it clean.


Establish a policy in your organization that allows this practice and follow it. This could include for example a documented conversation with the provider and CDI prior to making any changes. 


Of course, check with your compliance department first. 


Most guidance I’ve read leaves the decision of who can update the problem list in the hands of the facility, including the likes of AHIMA.


I have linked to a helpful AHIMA article on this issue below; AHIMA reminds us of the importance of recording and documenting any changes as follows: “The source for problem list updates or resolutions-that is, the authentication and identification for all health record entries-must be recorded. In order to maintain data integrity and fulfill legal requirements all pertinent dates must be captured and stored, including date and/or time noted or diagnosed, dates and/or time of any changes in problem specification or prioritization, and the date/time of resolution. Automated time stamps may be used where appropriate.”


How do you handle the problem list? Take the poll below; would love to see how this shakes out.


How does your organization handle updating the problem list?


  • Providers only can update it


  • CDI specialists update it


  • We have another process for update


  • We don’t have a process


  • Problem lists are not a problem!


AHIMA, “Problem list guidance in the EHR”: 

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