As if coders and clinical documentation improvement specialists aren't under enough pressure as it is, the advent of the 2017 Official Guidelines for Coding and Reporting brings to the table new documentation requirements for pressure ulcer coding. The guidelines can be viewed here: www.cdc.gov/nchs/data/icd/10cmguidelines_2017_final.pdf .
This article is part two of a two-part series on the definition changes for sepsis. Reread part one in the October issue of BCCS. In my October Clinically Speaking column, we discussed the evolution of the definition of sepsis and its implications in clinical care (Sepsis-1, Sepsis-2, and Sepsis-3), quality measurement (CMS' SEP-1 core measure), and ICD-10-CM coding compliance.
The recent adoption of a refined version of the Patient Safety Indicator (PSI) 90 composite by the Agency forHealthcare Research and Quality (AHRQ) has a significant impact on what discharges are included in PSI 15 (Unrecognized Abdominopelvic Accidental Puncture Laceration Rate).
The new guideline for code assignment and clinical criteria in the 2017 ICD-10-CM Official Guidelines for Coding and Reporting does not mean clinical documentation improvement is going away; instead it just upped the ante for continued improvement.
Just like the lyrics to the popular Gap Band song say, "You dropped a bomb on me… I won't forget it," there are definitely some changes in the 2017 ICD-10-CM Official Guidelines for Coding and Reporting that some of us may wish the Cooperating Parties will forget were ever mentioned.
With only 60 days between the OPPS final rule's release and the January 1 implementation date, providers will be ahead of the curve by spending time now and thinking about the processes they may need to review, change, or implement based on what CMS finalizes and the sort of financial impact the final rule is likely to have.
Q. Since ICD-10-CM code O24.415 (gestational diabetes mellitus in pregnancy, controlled by oral hypoglycemic drugs) has been added for 2017, do we need to add which specific drug is being used by the patient when reporting the code?
Facilities may not yet be using clinical documentation improvement staff to review outpatient records, but the increasing number of value-based payment models and Medicare Advantage patients could make the practice worthwhile, according to Angela Carmichael, MBA, RHIA, CDIP, CCS, CCS-P, CRC, and Lena Lizberg, BSN.
E/M reporting remains challenging for coders and an area of scrutiny for auditors. These challenges can be amplified in the ED, but coders can reduce confusion by reviewing rules for reporting critical care and other components.
CMS released the final rule implementing provisions of the Medicare Access and CHIP Reauthorization Act of 2015 on October 14, giving providers a timeline and outline of the quality programs and payment models that will replace the Sustainable Growth Rate and other programs.
The new ICD-10-CM codes activated October 1 affect nearly every section of the manual. Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC, CDIP, writes about codes that impact genitourinary and gynecological diagnoses with tips for reporting them accurately.
With all the hoopla over sepsis, pressure ulcers, and diabetes coding, there’s a little gem of coding advice that has been overlooked since ICD-10 was released: pneumonia and chronic obstructive pulmonary disease. Adrienne Commeree, CPC, CPMA, CCS, CEMC, CPIP , writes about these changes and helps to decipher the new guideline changes. Note: To access this free article, make sure you first register for the free content if you do not have a paid subscription.
In early August, hospitals got a last-minute reprieve from the Medicare Outpatient Observation Notice (MOON) notification requirement. CMS detailed the need for additional time to revise the standardized notification form that hospitals will need to use to notify patients about the financial implications of being assigned to observation services; and, as of now, the requirement is still in delay.
Trey La Charité, MD , writes about how he feels the days of merely maintaining compliance with published coding guidelines are gone, and suggests ways to protect a facility and appeal audits.
This October celebrates the eight month anniversary of the February release of the controversial third international consensus definitions for sepsis and septic shock. James S. Kennedy, MD, CCS, CDIP , tackles this new sepsis definition in part one of his two-part series.
Q: What is the correct procedure code for an esophagogastroduodenoscopy? Our coder coded 0DQ68ZZ (Repair, stomach, via natural or artificial opening, endoscopic), which groups to DRG 326, the same as an esophagectomy. The relative weight is 5.45. This does not seem right. Could you please clarify?
Q: We are struggling with how to report the functional status codes that are required when a physical therapist provides therapy services post-operatively. We have a process for doing that for our “regular” therapy patients, but are struggling with how to implement this for the outpatient surgeries.
Human papillomavirus is the most common sexually transmitted infection in the U.S. Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC, CDIP, reviews how to report vaccinations for the virus and how coverage policies by differ by carrier. Note: To access this free article, make sure you first register here if you do not have a paid subscription. Once you have set up your free registration, you can log in and access this article by clicking here.
The 2017 OPPS final rule is scheduled to be released in just a few weeks. Jugna Shah, MPH, writes about what facilities should be preparing for in case some of CMS’ proposals related to off-campus, provider-based departments, packaging, and device-intensive procedures are finalized.
Wound care procedures can be uniquely complicated due to the range of severity in injuries and potential need to incorporate measurements for multiple wounds. Review these coding tips and anatomical details for reporting wound care procedures.
More than half of the members of Congress have written to CMS to consider changes to its proposals for implementation of Section 603 of the Bipartisan Budget Act of 2015 regarding off-campus, provider-based departments.
Q: I am never sure of correct sequencing when the admission is for flu, pneumonia, and asthma. The patient presented in the emergency department (ED) with shortness of breath, still tight after nebulizer treatment in the emergency room. The patient was kept for observation for one day, then was admitted. Documentation includes: Fever 101.8 in ED; respiratory rate (RR) 24; white blood cell count (WBC) 12.6 Influenza and upper respiratory tract infection Mild persistent asthma in exacerbation due to the above (wheezing, tachycardia in the ED, 130s); acute hypoxic respiratory failure (PO 90%). Superimposed RLL community-acquired pneumonia (CAP), per chest x-ray Can you suggest proper sequencing and if queries are needed?
Adrienne Commeree, CPC, CPMA, CCS, CEMC, CPIP, discusses the new documentation requirements for pressure ulcer coding in the 2017 Official Guidelines for Coding and Reporting. Note: To access this free article, make sure you first register for the free content if you do not have a paid subscription.
Since the physician doesn't need to document a specific root operation, coders cannot rely solely on the terms the physician uses; thus it is important for each coder to fully understand each definition, including the root operations that put in, put back, or move some or all of a body part.
Shannon Newell, RHIA, CCS, writes about how certain hospitals will be required to participate in the Comprehensive Joint Replacement Model and a new orthopedic payment model called SHFFT if an August 2 proposed rule is finalized.
Billing correctly for observation hours is a challenge for many organizations. Getting it right requires knowing how to calculate observation hours for each patient, which is far from straightforward.
In the outpatient setting, we have a different set of rules to follow in regard to the ICD-10-CM Official Guidelines for Coding and Reporting compared to those that follow the guidelines for inpatient care. The ICD-10-CM guidelines for outpatient coding are used by hospitals and providers for coding and reporting hospital-based outpatient services and provider-based office visits.
The Medicare Reporting and Returning of Self-Identified Overpayments final rule (81 Fed. Reg. 7654‑7684), which became effective March 14, is designed to implement Section 1128J(d) of the Social Security Act, which was established under Section 6402(a) of the Affordable Care Act, effective March 23, 2010.
If your hospital resides in one of the 67 metropolitan statistical areas (MSA) required to participate in the Comprehensive Joint Replacement Model (CJR), you will also be required to participate in a new orthopedic payment model called SHFFT (surgical hip and femur fracture treatment) if an August 2 proposed rule is finalized.
In our computer-savvy tech world, the medical field has been notoriously slow to respond to newer technologies and applications of computer-assisted enhancements. However, in the HIM market, computer-assisted coding (CAC) has been touted to boost coding accuracy and productivity, in addition to being an important tool for the remote inpatient coder.
Resiliency is the ability to spring back or rebound. In sports, it's one of the mental attributes a player must have. Coders are resilient: bouncing back from one change after another, deciding to code smarter and faster, and having the patience to do whatever is expected?even amid closing grace periods and guideline controversies.
Shannon E. McCall, RHIA, CCS, CCS-P, CPC, CPC-I, CEMC, CRC, CCDS, delves into chapter-specific guidance included in the updated 2017 ICD-10-CM guidelines, including changes for diabetes, hypertension, pressure ulcers, and more.
As providers prepare for the thousands of new codes and updated guidelines to be implemented October 1, the ICD-10 Coordination and Maintenance Committee recently met to discuss the next batch of updates to be implemented October 1, 2017.
Q: We have a new pharmacy director and he wants to monitor all separately payable drugs to ensure that we receive appropriate reimbursement. We’re trying to figure out how to do this because the payment is subject to change each quarter. Do you have any suggestions?
Billing correctly for observation hours is a challenge for many organizations. Getting it right requires knowing how to calculate observation hours for each patient, which is far from straightforward. Janet L. Blondo, LCSW-C, MSW, CMAC, ACM, CCM, C-ASWCM, ACSW, writes about how to properly calculate hours and report observation services properly.
Shannon E. McCall, RHIA, CCS, CCS-P, CPC, CPC-I, CEMC, CRC, CCDS, continues her review of the updated 2017 ICD-10-CM guidelines by explaining how changes to sections for laterality and non-provider documentation will impact coders and physicians. Note: To access this free article, make sure you first register here if you do not have a paid subscription. Once you have set up your free registration, you can log in and access this article by clicking here.
Laurie L. Prescott, MSN, RN, CCDS, CDIP , writes that as many CDI teams work to expand their risk adjustment programs, a melding of two skill sets, that of CDI specialists and coding professionals, are required to succeed.
Since the physician doesn't need to document a specific root operation, coders cannot rely solely on the terms the physician uses; thus it is important for each coder to fully understand each root operation, including Restriction and Occlusion. Note: To access this free article, make sure you first register if you do not have a paid subscription.
Laura Legg, RHIT, CCS, CDIP , explains how the coming months will prove to be challenging for coders because of the new ICD-10 codes for both diagnoses and procedures beginning October 1. Along with that, we’ll see the end of the CMS grace period on code specificity for Part B physician payments and updated ICD-10-CM Official Coding Guidelines .
Q: I am with a CDI program that is starting to explore severity of illness/risk of mortality (SOI/ROM). I personally have been reviewing for SOI/ROM for quite a while. I usually designate the impact (MCC/CC/SOI/ROM) after the billing is done and see if what I queried for made a final impact, and only take credit for those that do. I was told that regardless of the actual final impact on SOI/ROM, we should be taking credit for any SOI/ROM clarification as SOI/ROM impact. Which is the most accurate, “correct” way to capture the CDI impact for these types of clarifications?
After an almost five-month deferment, the Beneficiary and Family Centered Care Quality Improvement Organizations resumed initial patient status reviews of short stays in acute care inpatient hospitals, long-term care hospitals, and inpatient psychiatric facilities, CMS announced on their website.
CMS recently released a fact sheet regarding the coding and billing of advance care planning services, following the release of a frequently asked questions document in July on the topic.
Updated ICD-10-CM guidelines, effective October 1, could cause confusion for some coders. Shannon E. McCall, RHIA, CCS, CCS-P, CPC, CPC-I, CEMC, CRC, CCDS, looks at how changes to reporting linking conditions measure up to previous guidance.
Coders may not be aware of the impact place of service codes can have on coding and billing. Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC, CDIP, writes about how the codes are used and what coders should know about their application.
Shannon E. McCall, RHIA, CCS, CCS-P, CPC, CPC-I, CEMC, CRC, CCDS, reviews additional changes to the ICD-10-CM guidelines for 2017, including coding and clinical criteria, new guidelines for Excludes1 notes, and updates for reporting pressure ulcers.
Q: Is it true that if the patient has hypertension and heart disease such as coronary artery disease that the coder may code the hypertension from the I11 (hypertensive heart disease) series of codes?
Sharme Brodie, RN, CCDS , discusses how to decipher between some potentially confusing—and possibly conflicting—information regarding diabetes documentation requirements.
Shannon Newell, RHIA, CCS, AHIMA-approved ICD-10-CM/PCS trainer, writes that the majority of the 2017 IPPS final rule updates are consistent with those outlined in the proposed rule, but contain a few refinements. She reviews refinements to the number of claims-based outcomes linked to payment.
Accurately reporting altered mental status and encephalopathy can be a challenge that requires coordination between coders and providers. James S. Kennedy, MD, CCS, CDIP, explains best practices for coding these tricky conditions. Note: To access this free article, make sure you first register if you do not have a paid subscription.
Q: The coders at my facility have started automatically linking congestive heart failure, hypertension, and chronic kidney disease (CKD) to the combination code without any documentation of CHF “due to” hypertension. There is no documentation of hypertensive heart disease anywhere in the record, and the diagnoses are not linked anywhere in the record.
CMS released a national coverage determination recently covering a percutaneous left atrial appendage closure through their “coverage with evidence development” policy. CMS says this policy will be fully implemented on October 3, 2016.
CMS released the 2017 OPPS proposed rule on July 5 without much fanfare. On July 14, the Federal Register version was posted, and upon initial review, it seems rather short at 186 pages.
The fiscal year (FY) 2017 IPPS final rule was released August 2 and will be published in the Federal Register August 22. The majority of the finalized updates are consistent with those outlined in the proposed rule, but with a few refinements to applicable time periods. The final rule expands and refines the number of claims-based outcomes linked to payment under these programs. Let's review a few of the key changes to support your CDI program's strategic focus for the coming year.
Last month, I wrote about the role of coding and CDI compliance in ensuring the clinical validity of submitted ICD-10-CM/PCS codes, which impact payment, outcomes measurement (e.g., complications, mortality, and readmissions), and patient safety.
CMS released the fiscal year (FY) 2017 IPPS final rule August 2, and ICD-10-CM/PCS code changes and the addition of the Medicare Outpatient Observation Notice (MOON) both had starring roles. CMS also made changes to several quality initiatives and reversed the agency's 0.2% payment reduction instituted along with the 2-midnight rule first implemented in the FY 2014 rule.
While the 2017 OPPS proposed rule includes a variety of tweaks and augmentations to existing regulations, its biggest impact is likely to come from its proposal to implement Section 603 provisions of the Bipartisan Budget Act of 2015 regarding off-campus, provider-based departments (PBD) and move toward more site-neutral payment policies.
CMS proposes aligning its conditional packaging logic with how it applies packaging to labs, while also proposing to delete the much-maligned modifier -L1 for separately payable laboratory tests in 2017.
CMS’ proposed changes to implement Section 603 of the Bipartisan Budget Act of 2015 would reshape payments for off-campus, provider-based departments (PBD) if finalized and represent the most significant changes in the calendar year (CY) 2017 OPPS proposed rule.
Richard D. Pinson, MD, FACP, CCS , discusses the new Sepsis-3 definition and how the classification has been the subject of great controversy and consternation since its publication in The Journal of the American Medical Association.
Robert Stein, MD, CCDS, and Shannon Newell, RHIA, CCS, co-author this article that provides insights into how clinical documentation and reported codes may impact payments and offer guidance on some common CDI challenges to strengthening data quality. Note: To access this free article, make sure you first register if you do not have a paid subscription.
A study conducted by Johns Hopkins Armstrong Institute for Patient Safety and Quality finds that common measures used by government agencies and public rankings to rate the safety of hospitals, such as the Agency for Healthcare Research and Quality’s patient safety indicators, and hospital-acquired conditions, do not accurately capture the quality of care provided.
Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC, CDIP , writes about how computer-assisted coding software can be used to boost coding accuracy and productivity, in addition to being an important tool for the remote coder.
Q: During an ICD-10-PCS Fusion, when a physician documents the use of a “structural allograft spacer” in the medical record, what sixth character would we use when coding this? Some colleagues say to use A (interbody fusion) and some say to use K (nonautologous tissue substitute). What would be the correct way to code this?
CMS is proposing to replace status indicator E (services not paid, non-allowed item or service) with two more specific status indicators in the 2017 OPPS proposed rule. The agency proposes status indicator E1 for items and services not covered by Medicare and E2 for items and services for which pricing information or claims data are not available.
While coders can choose among many CPT codes, provider documentation may sometimes not differentiate between similar options. Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC, CDIP, writes about some tricky procedures to distinguish and how coders can ensure they’re reporting which procedures providers actually performed. Note: To access this free article, make sure you first register here if you do not have a paid subscription. Once you have set up your free registration, you can log in and access this article by clicking here.
Jugna Shah, MPH, and Valerie Rinkle, MPA, recap CMS’ proposed changes to packaging logic in the 2017 OPPS proposed rule, as well as plans for new and deleted modifiers.
Q: Our surgeons perform a lot of blepharoptosis repairs. Because each patient is different, different amounts of eyelid tissue has to be removed. One of our surgeons wants to set a maximum amount that is included in the procedure and then charge a blepharoplasty to cover anything over and above this maximum. We are trying to figure out how to even start to operationalize this. It seems to us that this is just a “patient differential” in the surgery like you have in any other surgery. Is there any guidance or standard for this?
Debbie Mackaman, RHIA, CPCO, CCDS, reviews how CMS determines inpatient-only procedures and what changes the agency is considering in the 2017 OPPS proposed rule.
James Kennedy, MD, CCS, CDIP , offers his take on AHIMA’s recently published clinical validation practice brief. Given that AHIMA is one of the ICD-10 Cooperating Parties, their practice briefs must be read closely, and if agreeable, incorporated into one’s compliance plan. Note: To access this free article, make sure you first register if you do not have a paid subscription.
Shannon Newell, RHIA, CCS, writes about recently proposed modifications to Patient Safety Indicator 90, and how a fact sheet released by the measure's owner, the Agency for Healthcare Research and Quality, provides insights into what changes may lie ahead.
CMS released the fiscal year 2017 IPPS final rule August 2. ICD-10-CM/PCS code changes and the addition of the Medicare Outpatient Observation Notice had a starring role in the final rule.
Q: What exactly are diagnostic-related groups (DRG) 067 and 068 (nonspecific cerebrovascular accident [CVA] and pre-cerebral occlusion without infarct, respectively)? How do they differ from transient ischemic attack (TIA) or CVA?
Jugna Shah, MPH, and Valerie Rinkle, MPA, review changes in the 2017 OPPS proposed rule for providers to comment on, including site-neutral payments and comprehensive APC updates.
Modifier -58 describes a staged or related procedure or service by the same provider during the postoperative period. For outpatient hospitals, the postoperative period is defined as the same service date.
Deciphering documentation is frequently the most difficult aspect of coding. Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC, CDIP, writes about what documented information coders can use to assign codes—and what to do when that information is lacking.
CMS recently released a short guide aimed at teaching healthcare professionals how to use the Medicare National Correct Coding Initiative tools and the differences between types of edits.
Q: When our pharmacy mixes medications for infusion, they sometimes have to waste a part of the vial that was opened. They log this in the pharmacy log, which they keep in the department. We have been billing the full amount of the drug that was in the vial and have had no issues with getting paid. Our pharmacist came from a regional meeting and told us that this is going to change.
CMS' Transmittal 3523, issued May 13, is the quarterly July 1 OPPS update. In this transmittal, CMS briefly mentions billing physical and occupational therapy and speech-language pathology services provided in support of or adjunctive to comprehensive APC (C-APC) services under revenue code 0940 (general therapeutic services) rather than the National Uniform Billing Committee--defined revenue codes for these services (i.e., 042x, 043x, and 044x, respectively).
We as coders, clinical documentation specialists, and compliance officers, are actively invested in coding compliance, aren't we? AHIMA and ACDIS emphasize coding compliance in their codes of ethics. If we aren't interested in coding compliance, why are we reading newsletters named Briefings in Coding Compliance Strategies and other similar publications?
Modifier -58 describes a staged or related procedure or service by the same provider during the postoperative period. For outpatient hospitals, the postoperative period is defined as the same service date.
Healthcare organizations have become mass gatherers of data. But without sophisticated analytics, integrated IT tools, and processes to mine that data, they may not be able to take advantage of it.
CMS issued a final rule in June to revamp the way it pays for tests under the Clinical Laboratory Fee Schedule (CLFS), though the agency has pushed the start date back a year and worked to ease administrative burden based on public comments.
"You are your own best teacher," or so the old adage goes. Sure, goodies and gifts are great for recognizing high-quality documentation, but for CDI teams struggling to obtain physician buy-in, the best strategy may be found in their providers' own records.
The accurate capture of acute respiratory failure has been a long-standing challenge for CDI programs. The accurate reporting of this condition as a post-procedural event can be even more difficult.
Q: Is it appropriate to assign ICD-10-CM code Y95 (nosocomial condition) based on the documentation of healthcare-associated pneumonia (HCAP) or hospital-acquired pneumonia (HAP)? It is appropriate to assign the code for documented healthcare-associated conditions. Should this still be queried for specificity, and should the hospital-acquired condition (i.e., pneumonia) be coded as bacterial, viral, or something else?
The American Hospital Association recently released its response to CMS’ FY 2017 IPPS proposed rule. The letter, which was sent to CMS’ acting administrator Andrew Slavitt, was presented on behalf of approximately 5,000 AHA member facilities and 43,000 individual members.
Since the physician doesn't need to use a specific root operation term in documentation, coders should not rely solely on the term the physician uses. Coders need to know the definitions and the nuances of the root operations, especially those involving a device.
Laurie L. Prescott, MSN, RN, CCDS, CDIP, provides coders with tips on coding heart failure, obstetrics, and linking language, and also offers the latest guidance given by AHA Coding Clinic for ICD-10-CM/PCS ® on these topics.
Q: Can a hospital that is not a critical access hospital (CAH) bill professional charges on UB-04 claims, Type of Bill (TOB) 013X? I have not read anywhere that hospitals cannot bill this way, but usually when discussing revenue 96X and other professional revenue codes there is mention of CAHs only.
