CMS and Medicare Administrative Contractors are aware of certain issues regarding National Coverage Determinations and Local Coverage Determinations related to ICD-10 and working to resolve them as soon as possible, according to CMS.
Jugna Shah, MPH, and Valerie A. Rinkle, MPA, review newpolicies and regulations from CMS in the 2016 OPPS final rule, including a new comprehensive APC for observation.
CMS introduced several new HCPCS codes and added comprehensive APCs (C-APC), including one for observation, in the 2016 OPPS final rule, released October 30.
Q: We are an independent outpatient end-stage renal disease clinic. When we administer a blood transfusion (we do not bill for the blood) can we bill HCPCS code A4750 (blood tubing, arterial or venous, for hemodialysis, each) for the tubing used in the procedure and also A4913 (miscellaneous dialysis supplies, not otherwise specified) for miscellaneous supplies pertaining to administering the blood?
CMS finalized its proposals regarding the 2-midnight rule in the 2016 OPPS final rule, including moving responsibility for enforcement and education of the rule from Recovery Auditors to Quality Improvement Organizations (QIO). This latter change occurred October 1, 2015.
Providers know the drill for addressing and operationalizing CMS' annual IPPS and OPPS updates, along with the usual ICD-9-CM and CPT® coding changes. The industry has become used to CMS' timetable for releasing inpatient and outpatient proposed and final rules and knows that it has to be ready to go live with coding, billing, and operational changes October 1 and January 1, respectively.
Q: I have a question about coding infusion/injections in the ED prior to a decision for surgery. A patient comes into the ED with right lower abdominal pain. The physician starts an IV for hydration, gives pain medication injections, then does blood work and an MRI to rule out appendicitis. The blood work comes back with an elevated white blood count, so the patient is started on an infusion of antibiotics. Then the MRI results come in with a diagnosis of appendicitis. So a surgeon is called in to consult and take the patient to surgery. Can we bill the infusions/injections prior to the decision for surgery? I realize that once the decision is made, then the infusion/injections are off limits and are all included in the surgical procedure. But up until that time, can the ED charge the infusions/injections? They are treating the patient’s symptoms and can’t assume the patient will have surgery until the decision is made by the surgeon.
Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, CDIP, COBGC, AHIMA-approved ICD-10-CM/PCS trainer, provided documentation and coding examples for reporting breast care procedures and ICD-10-CM diagnoses.
Q: Our business office wants us to start using modifier -PO (services, procedures, and/or surgeries furnished at off-campus, provider-based outpatient departments) for services that are provided in some of our outpatient departments, but not all. We want to hard code this to our charge description master but are not sure why some services will get this modifier and some won't.
Charlotte L. Kohler, RN, CPA, CVA, CRCE-I, CPC, ACS, CHBC, discusses how modifiers -59 and -91 differ and what coders need to know to use them when reporting laboratory services.
Because CMS has not created any national ED E/M guidelines, providers must create their own criteria for each visit level. CMS has developed a list of 11 criteria that it uses when auditing facility E/M criteria.
Providers have to create their own ED E/M guidelines, which can present a variety of challenges for facilities. For coders, this means an understanding of how to calculate critical care and other factors in order to report the correct visit level.
Q: I have been told by our billers that infusion codes reported in the ED along with an E/M code that has modifier -25 (significant, separately identifiable evaluation and management service on the same day of the procedure or other service) require another modifier. I thought that -25 is the only modifier that should be submitted, unless the provider started a second infusion at a second site on the body. This is the first time I’ve been told the infusion coder need a modifier if the E/M has modifier -25 appended. All of my educational articles tell me that the two can be reported together. Have I missed an update somewhere along the way?
Combination codes in ICD-10-CM will allow coders to report pressure ulcer location and severity in a single code. Jaci Johnson Kipreos, CPC, CPMA, CEMC, COC, CPC-I, and Betty Hovey, CPC, CPC-H, CPB, CPMA, CPC-I, CPCD, review the stages of pressure ulcers and which information coders will have to look for in documentation.
OPPS costs rose approximately $1 billion more than expected in 2014 due to a CMS overestimation of the impact of laboratory packaging changes, according to the 2016 OPPS proposed rule. As a result, CMS proposes a 2% reduction to the 2016 conversion factor. CMS also proposes to expand laboratory packaging from date of service to the claim level.
The 2016 OPPS proposed rule released July 2 is deceptively short, but packs a punch. CMS is proposing the most massive APC reconfiguration and consolidation of APC groups since the beginning of OPPS, says Jugna Shah, MPH, president and founder of Nimitt Consulting, based in Washington, D.C., and Spicer, Minnesota.
The 2016 OPPS proposed rule introduces APC restructuring, new comprehensive APCs, and many other potential changes for next year. Jugna Shah, MPH, and Debbie Mackaman, RHIA, CPCO, CCDS, review the proposals and what they could mean for providers.
Q: I have a question regarding facility coding for evaluation and management (E/M) levels, not for an ED physician, but for facility-level nursing in the ED. If a specialist is called to evaluate or consult on a patient, the nursing intervention is what the facility-level criteria is based on. For example, a patient has difficulty walking, a nurse assists the patient to get an x-ray, takes vitals, does an initial assessment, then provides discharge instructions of moderate complexity. I would code this scenario as a level 3.
CMS has repeatedly tweaked its logic regarding comprehensive APCs since inception. Dave Fee, MBA, reviews the latest changes regarding complexity adjustments, as well as new and deleted codes.