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.
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 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.
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.
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.
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.
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.
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.
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?
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.
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.
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.
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.
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.
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.
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.
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?
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.
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.
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.
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.
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).
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.
"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.
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.
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?
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.
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.
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.
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.
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?
Providers must link the medical necessity of the treatment they give to the documented diagnoses or they may not get paid. Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC, CDIP, looks at how to ensure medical necessity is proven for fertility services.
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.
CMS’ 2017 OPPS and Medicare Physician Fee Schedule (MPFS) proposed rules, released July 6 and 7, respectively, introduce policies that focus on improving payment accuracy across sites and for professionals in primary care, care management, and patient-centered services.
Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC, CDIP, writes about the types of treatment for infertility for both men and women, highlighting the associated diagnosis and procedure codes used to report them.
Q: When a patient presents with acute respiratory failure, as well as an overdose, is it ever appropriate to assign the acute respiratory failure as principal diagnosis, since it is an acute condition that would have occasioned the admission to the hospital?
Paul Evans, RHIA, CCS, CCS-P, CCDS, give coders ICD-10-PCS documentation and coding tips for three of the most common, and commonly misunderstood, procedures performed via bronchoscopy.
