There was a far-ranging medication management discussion held at The Joint Commission’s 2019 Executive Briefings this September. Led by Robert Campbell, PharmD, a pharmacist with The Joint Commission’s Standards Interpretation Group, the panel covered everything from medication compounding, opioids and painkillers, and syringe use.
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Tag Archives: Joint
Joint Commission revises scoring for infection control as of September 1
On September 5, The Joint Commission (TJC) announced scoring changes for its IC.02.02.01 standard, which requires facilities to reduce infection risk associated with medical equipment, devices, and supplies. The standard was third on TJC’s recent list of most challenging requirements for hospitals.
Potential Genicular nerve & Si Joint Ablation Codes in 2020
In the 2019 OPPS/ASC final rule, it appears CMS published a comment from someone who states they are aware of the planned creation of CPT codes for radiofrequency ablation of genicular nerves and SI joint in 2020
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https://s3.amazonaws.com/public-insp…2018-24243.pdf
Summary of Comment Page 321-322
The commenter also recommended that CMS develop two new HCPCS G-codes to describe the performance of radiofrequency nerve ablation procedures. The commenter suggested that one of the G-codes could be created to describe procedures involving the genicular nerve, and the other G-code could be created to describe procedures involving the sacroiliac joint. The commenter further recommended that both of these G-codes be created to describe procedures describing non-opioid treatment alternatives for chronic pain management, and to assign both of these newly created G-codes to Level 2 Nerve Procedures APC 5232 based on its recommended three-level APC structure, with an estimated payment rate of $ 2,431. The commenter was aware that Category I CPT codes are in development, but will not be ready for release until CY 2020 at the earliest.
Summary of Response
With regard to the request to establish new HCPCS G-codes, although new CPT codes are in development for release for the CY 2020 update, we note that it does not appear that a request for new temporary Category III codes was made for CY 2019. Nonetheless, we intend to take the commenters request for new HCPCS G-codes under advisement.
Medicare Program: Changes to Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs
17. Nerve Procedures and Services (APCs 5431 through 5432)
Comment: One commenter suggested that CMS restructure the two-level Nerve Procedure APCs (APCs 5431 and 5432) to provide more payment granularity for the types of procedures included in the APCs by creating a third level. The commenter believed that there is a substantial payment differential between the procedures assigned to Level 1 Nerve Procedures APC 5431 and Level 2 Nerve Procedures APC 5432, and that the current payment for some of these procedures does not adequately cover the cost of providing the services. The commenter further stated that, as an example, the procedures described by CPT codes 64633 (Destruction by neurolytic agent, paravertebral facet joint nerve(s), with imaging guidance (fluoroscopy or CT); cervical or thoracic, single facet joint) and 64635 (destruction by neurolytic agent paravertebral facet joint nerve(s), with imaging guidance (fluoroscopy or CT); lumbar or sacral, single facet joint), which are assigned to APC 5431 with a proposed payment rate of approximately $ 1,644, while the geometric means for each of the procedures described by CPT codes 64633 and 64635 are $ 1,482 and $ 1,729, respectively. The commenter recommended a potential geometric mean cost for a potential three-level APC structure within the Nerve Procedures APCs and submitted a three-level APC structure, along with estimated payment rates, which is shown in the table below.
The commenter also recommended that CMS develop two new HCPCS G-codes to describe the performance of radiofrequency nerve ablation procedures. The commenter suggested that one of the G-codes could be created to describe procedures involving the genicular nerve, and the other G-code could be created to describe procedures involving the sacroiliac joint. The commenter further recommended that both of these G-codes be created to describe procedures describing non-opioid treatment alternatives for chronic pain management, and to assign both of these newly created G-codes to Level 2 Nerve Procedures APC 5232 based on its recommended three-level APC structure, with an estimated payment rate of $ 2,431. The commenter was aware that Category I CPT codes are in development, but will not be ready for release until CY 2020 at the earliest. Therefore, the commenter requested that CMS create such G-codes in order to allow for physicians and hospitals to report the performance of the procedures and use of the approach, and to be paid for utilization of these procedures in the interim. The commenter supplied a suggested descriptor for the G-code for the genicular nerve as: Radiofrequency nerve ablation; genicular nerves, including imaging guidance, when performed. The commenter also supplied a suggested descriptor for the APC Level Number of Singles Used to Calculate APC Geometric Mean Total Frequency of Claims APC Geometric Mean Cost Estimated Payment Rate Number of HCPCS Codes 2 Times Rule Violation 5431 113,284 116,158 $ 1,583 $ 1,555 15 0 5432 15,035 17,051 $ 2,476 $ 2,431 58 0 5433 1,757 1,763 $ 5,373 $ 5,276 28 0 G-code for the sacroiliac joint as: Radiofrequency never ablation; sacroiliac joint, including imaging guidance, when performed. Response: We appreciate the commenters suggestions. However, at this time, we believe that the current two-level structure Nerve Procedures APCs provide an appropriate distinction between the resource costs at each level and clinical homogeneity. We will continue to review the APCs structure to determine if additional granularity is necessary for this APC family in future rulemaking. In addition, we believe that more analysis of such groupings is necessary before adopting such change. With regard to the request to establish new HCPCS G-codes, although new CPT codes are in development for release for the CY 2020 update, we note that it does not appear that a request for new temporary Category III codes was made for CY 2019. Nonetheless, we intend to take the commenters request for new HCPCS G-codes under advisement. Therefore, after consideration of the public comment received, we are finalizing our CY 2019 Nerve Procedures APCs two-level structure, as proposed. We refer readers to Addendum A to this final rule with comment period for the complete list of APCs and their payment rates. In addition, we refer readers to Addendum B to this final rule with comment period for the payment rates for all codes reported under the OPPS. Both Addendum A and Addendum B are available via the Internet on the CMS website.
Implications of the Joint Commission’s 2016 deletions for staff education and training requirements for 2017
This article was written by Marlene K. Strader, RN, PhD, and Elizabeth Di Giacomo-Geffers, RN, MPH, CSHA, a healthcare consultant in Trabuco Canyon, California, and a former Joint Commission surveyor.
In the first quarter of 2016, there were 46 topics that were required for education and training of hospital staff, including physicians, nurses, and other allied healthcare personnel. In May 2016, The Joint Commission deleted many standards and elements of performance (EP), reducing the number to around 40. A few of those deletions impact the Human Resources (HR) chapter as well as other chapters.
SC joint reconstruction with allograft
One of my surgeons is performing Sternoclavicular joint reconstruction with allograft tendon and I am looking at 21740. Can someone tell me if I am looking in the right direction?
Thank you!
Joint Commission surveyor focus remains on EC, LS, ligature risks
Some of the top takeaways for environment of care and other healthcare and quality professionals attending The Joint Commission’s (TJC) annual Hospital Executive Briefings held September 14 in New York City.
The Joint Commission deletes 225 standards
JC quarterly update
The Joint Commission deletes 225 standards
by Jean S. Clark, RHIA, CSHA
The May 2016 issue of Perspectives outlined 225 hospital requirements from the accreditation manual?nine from the Information Management (IM) chapter and five from the Record of Care, Treatment and Services (RC) chapter?that have been deleted. This initiative is part of the Joint Commission’s project REFRESH and improving the survey process. Deletions fell into three categories:
1.Those that were duplicative of or implicit in the element of performance
2.Those that were a routine part of operations or clinical care processes
3.Those that were adequately addressed by external requirements
The largest number of deletions fell into those that were a routine part of operations or clinical processes. The good news is that we now have fewer standards/elements of performance to contend with. The bad news is that the majority of the IM and RC chapter deletions fell into the duplicative category, so we still have to be compliant in other standards. Let’s take a look at what was deleted and where requirements can now be located.
As you can see, the majority of the deletions are duplicative, which means the standards did not go away entirely. My advice is to review the deletions and compare your compliance with the referenced standard or requirement. Don’t become complacent just because some standards have been removed! And take time to review the other standards identified in the May 2016 issue of Perspectives, especially the Provision of Care deletions. The good news here is that all hospitals, regardless of deemed status, will be using the CMS restraints and seclusion requirements.
Editor’s note
Clark is a consultant, author, and speaker with more than 30 years of experience in HIM, accreditation, and regulatory compliance. Contact her at [email protected]. Opinions expressed are that of the author and do not represent HCPro or ACDIS.
Joint Injections
I have an ortho provider who is refusing to document his procedure further than "today we injected the knee with 40mg kenalog" I am trying to explain to him that any and all procedures should include at minimum: 1) Indications for procedure (medical necessity) 2) Anesthesia/Medication given (include dosage) 3) What was done with some detail site, approach, equipment used, findings 4) Closure of wound (if appropriate) 5) Any complications 6) Patient’s condition at end of procedure. He wants something from the aaos or cms stating this is required and for the life of me I cannot locate guidelines that clearly support any or all of these item. Our templates in the system are built to include this info but he is not using them.
Q&A: Joint Commission talks ligature risk
In a live question-and-answer session, Kathryn Petrovic, MSN, RN-BC, The Joint Commission’s (TJC) field director of surveyor management and development, and Emily Wells, CSW, MSW, TJC’s project director of surveyor management and development, offered answers to some of those questions.
RFA Sacroliliac Joint
This one has me a little stumped.. My doctor wants to code: 64635, 64640 x 3; I’m seeing 64635/64636 x2;
The op report reads:
Procedure: Left Radio-frequency ablation sacroiliac joint, specifically the dorsal ramus of L5 and lateral branches of S1, S2 and S3
After obtaining consent, the patient was placed in prone position. I identified the sacral ala and the superior articular process of S1. I prepped the area with chlorhexdine in the usual sterile fashion technique. I used lidocaine 2% for skin infiltration. I advanced the needle until I had good position of the junction between the sacral ala and the superior articular process of the left S1. Then we identified the most median and superior part of the left SI joint. I advanced the needle towards the most lower and inferior portion of the SI joint on the left side until I had good position of the needle into the above level in the AP and lateral views. The following technique was used to confirm placement at the median branch nerves.
Sensory stimulation was applied to each level at 50Hz; parenthesis were noted below 0.6 micro-volts. Motor stimulation was applied at 2Hz with 1 millisecond duration. corresponding paraspinal muscle twitching without extremity movement was noted. Following this, the needle trocar was removed and a syringe was removed and a syringe containing 0.25% bupivicaine was attached. At each level, after syringe aspiration with no blood return, 1 mL of 0.25% bupivicaine was injected to anesthetize the median branch nerve and surrounding tissue. After completion of each nerve block, a lesion was created at that level with a temperature of 80 degrees Celsius for 90 seconds. All injected medications were preservative free. Sterile technique was use throughout the procedure.
Any insight would be greatly welcome!!!!