Post-Merger HIM: DNFB, ROI, and a Registry Deadline in the Same 30 Days

Regulatory deadlines beat cash timing when the deadline cannot be recovered.

1. Release of information - first. 900 open requests with 540 beyond the 30-day right-of-access window is an active, ongoing compliance failure with a documented exposure path (OCR complaints, patient complaints, state attorney general attention). Unlike cash, missed access deadlines cannot be cured retroactively. Assign staff this week.

2. Cancer registry - second, and it is already short. Capacity check: 2 abstractors × 2.5 charts/day × 20 days = 100 charts against 180 due - an 80-chart shortfall, i.e. the team needs to be roughly 3.6 FTE-equivalent for the next 30 days to make the deadline. Commission reporting deadlines drive accreditation status and, downstream, payer and CoC implications. Do the arithmetic in the meeting; the shortfall is not a matter of effort.

3. DNFB - third on urgency, largest on dollars, and the only one that is purely recoverable. $21.6M of revenue is deferred, not lost, as long as filing limits are not breached. That is the constraint to watch.

The COO is right about magnitude and wrong about sequencing. Say so with the arithmetic, not with an opinion.

The tempting calculation:

• Uncoded value: 2,300 × $9,400 = $21,620,000
• Closing a 12-day DNFB gap accelerates that cash by roughly 12 days: $21,620,000 × 6% × 12/365 = about $42,600 in carrying cost avoided.
• Agency premium: 2,300 × ($18 − $11) = $16,100.

So on paper, $16,100 buys $42,600 of benefit - a favorable ratio. But the calculation is fragile:

1. It assumes the agency coders clear all 2,300 charts within the 12 days, which ignores credentialing, EHR training, and a two-to-four-week productivity ramp. A first-week agency coder may produce 40% of an internal coder's output.
2. It assumes the backlog is the only cause of the 12-day gap. It is not - a 26% vacancy is the binding constraint, and agency coders treat the symptom.
3. Carrying cost is the smallest part of the exposure. The real risk is filing limits: a commercial payer's 90- to 180-day filing window from date of service expires regardless of internal backlog, and an untimely claim is a permanent write-off, not a delay.

Recommendation: approve a time-boxed agency engagement, but justify it on filing-limit and denial risk, and require a productivity floor and ramp schedule in the contract. Do not present it to finance as a cost-of-capital arbitrage - that argument will not survive scrutiny.

What to tell the COO:

• "The cash is deferred, not lost - unless a filing limit expires, and some will if we do nothing. The ROI backlog and the registry shortfall are losses we cannot get back; that is why they go first."
• Give the registry arithmetic explicitly: 100 charts of capacity against 180 due. This is the kind of number that changes a resource decision in one sentence.
• Ask for one concrete trade: temporary abstractor support and ROI overtime for 30 days, funded from the agency-coder budget line, in exchange for which DNFB gets a weekly recovery plan. Executives respond to a trade, not a list of problems.
• Flag the vacancy as the structural issue: 7 of 27 unfilled is a recruitment and compensation problem, not a productivity problem, and no amount of backlog triage fixes it.

Three KPIs, reported weekly during the recovery:

1. DNFB in days, plus the count of accounts approaching each payer's filing limit - the filing-limit count is the one that predicts write-offs.
2. ROI requests past 30 days, as a count and an aging bucket - a compliance measure, not a throughput measure.
3. Registry abstracts remaining against working days remaining - a burn-down, because a percentage complete hides the capacity gap.

Each KPI needs an owner and a threshold that triggers escalation. Reporting a metric no one is empowered to act on is how the 22-day DNFB happened in the first place.