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Ready CDI teams for CMS’ proposed expansion of mandatory ortho episode payment models
by Shannon Newell, RHIA, CCS, AHIMA-approved ICD-10-CM/PCS trainer
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. The impact? The following assigned MS-DRGs will no longer define hospital reimbursement:
MS-DRGs 469 and 470 are included in the CJR, which we have discussed in prior articles. Let’s take a look at the proposed SHFFT episode payment model (EPM), which involves the other three MS-DRGs, and see what role the CDI program can play as reimbursement shifts to episode-based payments.
Model overview
The episode of care defined for the SHFFT EPM begins with an admission to a participating hospital of a fee-for-service Medicare patient assigned MS-DRGs 480?482. This admission is referred to as the anchor hospitalization. The episode continues 90 days post-discharge from the hospital, and payments for all related Part A and Part B services are included in the episode payment bundle. CMS holds the hospital accountable for defined cost and quality outcomes during the episode and links reimbursement?which may consist of payment penalties and/or financial incentives?to outcome performance.
This is a mandatory EPM for hospitals already impacted by the CJR; the SHFFT model will apply to the same 67 geographic MSAs. The EPM is proposed to begin July 1, 2017, and will last for five years, ending in December 2021.
Cost outcomes
CMS will initially pay the hospital and all providers who bill for services during the episode using the usual fee-for-service models. Thus, the SHFFT EPM will not impact the revenue cycle at first. However, at the end of each performance period, which typically represents 12 months (January through December), CMS will compare or reconcile the actual costs with a preestablished "target price."
CMS will set target prices using an approach that will phase in a blended rate of hospital to regional costs. In recognition of the higher costs associated with discharges in MS-DRGs with an MCC or CC, CMS has developed an algorithm to adjust the target price for this subset of the patient population.
If the reconciliation process indicates that the costs to deliver services for the episode were higher than the target price, CMS will require repayment from the hospital. If, however, the costs to deliver care for the episode were lower than the target price, CMS will provide additional payments to the hospital for the provided services. To receive additional payments, however, performance for defined quality outcomes must meet or exceed established standards.
Quality-adjusted target price
To receive any earned financial incentives, the hospital must meet or exceed performance standards for established quality outcomes. CMS therefore adjusts the target price based on quality performance, referred to as the quality-adjusted target price.
The SHFFT EPM uses the exact same quality outcomes as those defined for the CJR:
Hospital (accountable party), collaborators, and Advanced Payment Models
The hospital is held accountable for episode cost and quality outcomes and all associated financial risks/rewards, even though a variety of providers deliver services and impact performance. As with the CJR, the hospital has been designated as the accountable party because CMS believes the hospital is best positioned to influence coordinated, efficient delivery of services from the patient’s initial hospitalization through recovery.
CMS permits the hospital to enter into collaborative arrangements with physicians and other providers to support and redesign care delivery across the episode and to share financial gains and/or losses. The proposed rule expands the list of collaborators defined in the previous CJR final rule to include other hospitals and Medicare Shared Savings Program accountable care organizations.
The proposed rule also provides an Advanced Payment Model (APM) track for the EPMs, an important step that will further incentivize collaborator participation.
CDI program opportunities
There are five key ways that clinical documentation and reported codes across the continuum impact SHFFT performance:
The costs associated with Part B claims are included in episode costs if the services are related. The primary diagnosis for each visit determines whether the visit is related.
The capture of at least one condition for each of the 28 comorbid categories over the 12-month period will strengthen risk adjustment and RSCR performance. RSCR performance contributes to 50% of the quality composite score, which, in turn, impacts the quality-adjusted target price.
Summary
Together the CJR and SHFFT models cover all surgical treatment options (hip arthroplasty and fixation) for Medicare beneficiaries with hip fractures. These MS-DRGs typically represent one of the largest inpatient surgical volumes for most short-term acute care hospitals.
As hospitals and collaborators assess and refine the management of patients to achieve or exceed the quality-adjusted target price, the data we submit on claims will be used to assess our performance. The CDI program in the inpatient and ambulatory setting must be positioned to promote and support the capture and reporting of impactful documentation.
Additional information on the proposed rule can be located at https://innovation.cms.gov/initiatives/epm.
Editor’s note
Newell is the director of CDI quality initiatives for Enjoin. Her team provides CDI programs with education, infrastructure design, and audits to successfully and sustainably address the transition to value-based payments. She has extensive operational and consulting expertise in coding and clinical documentation improvement, case management, and health information management. You can reach Newell at 704-931-8537 or [email protected].
Computer-assisted coding: Where are we today?
by Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC, CDIP
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.
Background
The term CAC denotes technology that automatically assigns codes from clinical documentation for a human to review, analyze, and use, according to the Journal of AHIMA.
Currently, there are a variety of methodologies, software, and integration interface applications that enable a CAC application to read text and assign codes. This type of software reads the information in a similar way to how a spell-check application works on a traditional computer. According to some users, data-driven documentation (e.g., documentation that is dictated or typed) is more accurately processed by the CAC software than documents that are scanned into the system for the software to use.
CAC software works through recognition; it learns words and phrases, as well as learning the areas within a specific document where standardized words and phrases appear. CAC software also has the ability to discern the context or meaning of those words and phrases. The program then analyzes and predicts what the appropriate ICD-10-CM/PCS codes should be for the documented diagnoses and procedures it finds within the specified documents.
Software providing CAC functionality has been available for over 10 years, but it has come to the forefront of inpatient coding with the implementation of ICD-10-CM/PCS. CAC has allowed hospitals to reduce lag times and enhance DRGs while also finding missed MCC/CC diagnoses. The usage and integration of an electronic health record (EHR) has also played a role in better code assignment and usage for data analysis and outcomes.
It is yet to be shown whether CAC actually enhances a coder’s productivity rate. On the upside, CAC does give the coder a great place to start when working on a difficult inpatient record. CAC is now where we were more than 20 years ago when encoders were first introduced into the inpatient hospital marketplace for coding, abstracting, and data analysis.
Pros and cons of CAC
Due to the complexity of inpatient care records, clinical documentation, and the complexity of medical terms and abbreviations, many hospitals only use CAC together with intervention by human coders. However, the latest CAC software technology employs a type of natural language and syntax processing to compare, contrast, and extract specific medical terms from electronic data or typed text?so CAC stand-alone technology does exist. In studies conducted by AHIMA, though, the combination of a CAC with a coder/auditor has been proven to be just as good, or better than, a coder or CAC alone.
The biggest challenge CAC poses might be getting buy-in from the hospital coding and HIM staff. The HIM, coding, and clinical staff must all be a part of the changes and be on board with learning how to use this technology enhancement. In the past, there has been some uncertainty and fear related to CAC eliminating coders’ jobs. However, a good CAC solution in conjunction with HIM management allows coders to apply their critical thinking and analytical skills to create well-coded documentation of patients’ care. This, in turn, results in more accurate DRG assignment and reimbursement for the facility.
HIM and coding staff’s responsibility and role in the fiscal revenue stream will change as a result of CAC and similar technology. With this change must comes the acceptance that it takes both a human and a computer to successfully transform a CAC product into good financial outcomes and even better documentation.
As coders will surely agree, the final code selection for inpatient records should be based upon coders’ knowledge of coding guidelines, clinical concepts, and compliance regulations. When working with CAC, the coder has the ability to agree with or to override codes that the software determines.
Coders have the education to understand why a diagnosis or procedure should or should not be coded in a specific situation, and by using CAC, they can help the software learn to identify the importance of specific documentation and its relation to ICD-10-CM/PCS codes.
Many CAC vendors will try and sell their product based on the following list of features and benefits:
As we’ve said, it hasn’t been shown that CAC actually increases coders’ productivity. In reality, their productivity will probably stay the same, as a coder will still have to audit the information to determine whether the code generated by the software is correct. But in regard to the other CAC benefits on the above list, coder satisfaction should not be overlooked.
During AHIMA’s pilot testing of CAC software, the organization weighed in on some of the potential issues with using CAC software alone (with no human intervention). AHIMA noted that within specific areas of the pilot CAC testing in ICD-10, the coders did not accept 75% of the diagnosis codes presented, and they did not accept 90% of the procedure codes presented within the code sets. However, the information that the CAC software presented did give the coders a good starting reference to drill down to a more comprehensive diagnosis or procedure code.
Coders and CDI personnel will still need to be in charge of the following:
CAC, clinical documentation, EHR, and providers
Integration of clinical documentation from providers and physicians has always been a challenge, and combined with the implementation of ICD-10, it has presented a huge impetus for the adoption of CAC technology in hospital- and facility-based organizations.
Unfortunately, physicians still don’t provide thorough documentation, instead relying on CDI and coding staff to guide them. There has always been a disconnect in the language spoken by providers and the language spoken by coders. Physicians document in their comfort zone and fall back on terms such as "pneumonia," whereas a coder is looking for much more specificity. The integration of an EHR-based program and CAC for providers can lead to a good team relationship for both parties.Many CAC programs integrate well with hospital-based CDI programs and EHRs. These combination interfaces allow more real-time processing of possible code selection prior to the coder’s audit and review of the final code selection.
When the CAC software identifies these possibilities, there is an opportunity to identify and improve the DRGs with MCCs and CCs, as well as more quickly address areas for query and missed procedures or diagnoses.
Wrapping it all up
It is evident that coders and HIM professionals need to make a commitment to embrace change, which includes new technologies and integration of learning processes and opportunities. A hospital’s success depends on the coder acting as part of a team that will strive for successful outcomes for both the patient and the hospital.
Editor’s note
Webb is an E/M and procedure-based coding, compliance, data charge entry, and HIPAA privacy specialist with more than 20 years of experience. Her coding specialty is OB/GYN office/hospitalist services, maternal fetal medicine, OB/GYN oncology, urology, and general surgical coding. She can be reached via email at [email protected], and you can find current coding information on her blog at http://lori-lynnescodingcoachblog.blogspot.com. This article originally appeared on JustCoding, and opinions expressed are those of the author and do not represent HCPro or ACDIS.
Key attributes for coders moving forward amidst the 2017 coding guideline changes
by Laura Legg, RHIT, CCS, CDIP, AHIMA-approved ICD-10-CM/PCS trainer
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.
The change to ICD-10 in October 2015, was a solid transition, and no one in healthcare was affected by it more than coders. The changes didn’t stop there. The coming months will again prove to be challenging for coders because of the new ICD-10 codes for both CM and PCS beginning October 1, 2016. Along with that, we’ll see the end of the CMS grace period on code specificity for Part B, and updated ICD-10-CM Official Coding Guidelines. Coders have a lot to learn this fall.
The Centers for Disease Control and Prevention published guidelines for discharges effective October 1, 2016, that have been approved by the four organizations that make up the Cooperating Parties for ICD-10-CM: the American Hospital Association, the American Health Information Management Association, CMS, and the National Center for Health Statistics.
The guidelines are available at www.cdc.gov/nchs/data/icd/10cmguidelines_2017_final.pdf. In the linked document, the changes are indicated in bold type for easy identification. Below are some of the highlighted changes.
Excludes1
This guideline supports the interim advice published last fall. Here, the Cooperating Parties have given instructions that two conditions unrelated to each other represents an exception to the Excludes1 definition. If it is not clear whether the two conditions are related, coders must query the provider.
With
Under Section I.B.7 of the guidelines, "multiple coding for a single condition" clarification has been added for interpretation of the word "with."
The word "with" should be interpreted to mean "associated with" or "due to" when it appears in a code title, the Alphabetic Index, or an instructional note in the Tabular List. The classification presumes a causal relationship between the two conditions linked by these terms.
These conditions should be coded as related even in the absence of provider documentation explicitly linking them, unless the documentation clearly states the conditions are unrelated. For conditions not specifically linked by this term in the classification, provider documentation must link the conditions in order to code them as related.
Code assignment and clinical criteria
Also under Section I, the Official Guidelines for Coding and Reporting tell us that the assignment of a diagnosis code is based on the provider’s diagnostic statement that the condition exists. The provider’s statement that the patient has a particular condition is sufficient. Code assignment is not based on clinical criteria used by the provider to establish the diagnosis.
Coders are instructed to assign a diagnosis or procedure code according to physician documentation. Coders have been told in the past not to question the physician’s clinical judgment. This appears to be pretty simple until audits from outside the organization place more emphasis on the use of clinical criteria. This use of clinical criteria to assign reported codes is known as "clinical validation." When coders follow the official coding guideline instructing them that a code assignment is not based on clinical criteria used by the provider to establish the diagnosis, they will be caught between following the guideline as instructed and being presented with a claim denial based on the absence of clinical validation.
In today’s healthcare environment, it is essential that organizations face this issue head on and provide coders with guidance on how to solve the dilemma of a record that contains physician documentation but does not contain clinical validation. Clinical documentation improvement efforts to improve upon complex clinical condition documentation must continue to bring the coding and medical records together to allow coders to code correctly and avoid payer denials.
CMS must clarify the reason the Recovery Auditors are allowed to deny claims, whether auditors will bypass this official coding guideline, and how organizations can reconcile the discrepancy.
Laterality coding
This update clarifies that when a patient with a bilateral condition has surgical correction on both sides, the first side corrected is coded with the bilateral code. The second site is not coded using the bilateral code because the condition no longer exists on the corrected side. If the treatment on the first side did not completely resolve the condition, then the bilateral code is used.
Documentation for BMI, non-pressure ulcers, and pressure ulcer stages
Section I.B.14 says for body mass index (BMI), depth of non-pressure chronic ulcers, pressure ulcer stage, coma scale, and NIH Stroke Scale (NIHSS) codes, code assignment may be based on medical record documentation from clinicians who are not the patient’s provider. Dietitians often document the BMI, nurses often document pressure ulcer stages, and an emergency medical technician often documents the coma scale. Keep in mind the associated diagnosis must be documented by the patient’s provider. A query should be used to clarify any conflicting medical record documentation.
This guideline shows the addition of the coma scale and NIHSS to conditions where code assignment can be determined from clinicians who are not the patient’s provider. Many coders may not be familiar with the NIHSS?it is a 15-item neurologic examination used to evaluate the effect of acute cerebral infarction. The NIHSS evaluates:
The NIHSS evaluation is often done by nursing staff and can help physicians quantify the severity of a stroke in the acute setting.
Zika virus infection
The official guidelines instruct coders to code only confirmed cases of the Zika virus with code A92.5 as documented by the provider. Note that this is an exception to the hospital inpatient guidelines. "Confirmation" does not require documentation of the type of test performed; the physician’s diagnostic statement that the condition is confirmed is sufficient. Documentation of "suspected," "possible," or "probable" Zika is not assigned to code A92.5.
Hypertensive crisis
A coding guideline has been added to instruct coders to assign a code from category I16 for hypertensive urgency, hypertensive emergency, or unspecified hypertensive crisis. This may call for some physician documentation education to make physicians aware that these more specific codes are available and can be used instead of documentation of hypertension without any further description.
Coma scale
In addition to using the coma scale codes (R40.2-) for traumatic brain injury codes, acute cerebrovascular disease codes, or sequelae of cerebrovascular disease codes, the coma scale may be used to assess the status of the central nervous system for other non-trauma conditions. Examples include monitoring patients in the ICU regardless of their medical condition.
Observation
One observation Z code category has been added for use when a newborn patient is being observed for a suspected condition that is ruled out. The new code category is Z05: encounter for observation and evaluation of newborn for suspected diseases and conditions ruled out.
Newly added ICD-10 codes
CMS will implement an unprecedented number of new code changes October 1. A partial code freeze prevented regular updates for the last five years, resulting in the release of over 5,000 ICD-10 revisions on that date. The newest coding updates can be found at https://www.cms.gov/Medicare/Coding/ICD10/Latest_News.html.
The new ICD-10 codes come as we thaw out from the code freeze that has been in effect since October 1, 2011. Since that time, we have received only limited code updates to both the ICD-9 and ICD-10-CM/PCS code sets. Now, the long delay is over. ICD-10-CM changes include 1,928 diagnosis code changes with expanded code choices for atrial fibrillation, heart failure, diabetes mellitus Type 2, disorders of the breast, and pulmonary hypertension.
Extensive PCS updates are also being implemented. There are 3,651 new PCS codes, revised code titles, and a grand total of 75,625 valid codes with this update. It is important to note that 87% of the PCS code updates are in the cardiovascular system.
Following adoption of the new codes, review of coding accuracy will be needed. Any misconceptions or incorrect rationale should be recognized and communicated early to prevent ongoing or costly patterns from developing. Remember to ensure software updates are also in place and scheduled on time.
The new cardiovascular PCS codes include:
Other PCS changes include:
The impact of the new codes will depend on what you do, so it’s important for hospitals to assess how the changes will affect them specifically. If you don’t deal with the areas where the codes have changed, the updates will be much easier than if your facility uses all the affected codes. Make sure the applicable codes are integrated into your internal applications and processes, while verifying that vendor products support the new codes. You don’t want to have claims rejected because not all of the new codes were incorporated.
Overall, there are moderate changes to the Official Guidelines for Coding and Reporting. The 2017 coding updates, however, are extensive and may seem overwhelming to some coders. The addition of over 10,000 codes after only one year of using ICD-10 will require coder resiliency to learn them all and understand how to apply them.
My experience has been that since the subscriber holds the relationship with the payer, they need to call to negotiate in network repricing. If they patient is unsuccessful then the provider can do an underpayment appeal on behalf of the member with UCR rates by calculating RBVS and an average of in network rates however because the provider appeals on behalf of the patient they forfeit being able to bill the patient at that point.
Also, when it comes to balance billing there are certain states that have laws against balance billing patients even in the event the provider is out of network.
I have also working for insurance companies processing claims and we would process any lab claims as in network if the ordering provider was in network but the lab was out of network. This was with BCBS so I am not sure if any other insurance companies will process the same way. Also, if the member is PPO member with BCBS they should get in network services anywhere they go.
I need resources and suggestions on how labs can successful obtain payment when out of network. It is very hard to compete with large lab corporations but there is also a need for smaller labs that specialize in particular lab tests. Also, the patient does not have a choice in where their labs are being sent so we want to help them as well and keep a good relationship with our clients.
Navigating the 2017 pressure ulcer coding changes in newly released guidelines
By Adrienne Commeree, CPC, CPMA, CCS, CEMC, CPIP
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.
Considering that these conditions impact length of stay, require additional monitoring and nursing care, and ultimately affect reimbursement for facilities, it’s no wonder coding for these conditions is under increased scrutiny. However, with a solid understanding of these types of ulcers, taking the time to read and understand the coding requirements can alleviate the "pressure" of ulcer codes.
New terminology
In April, the National Pressure Ulcer Advisory Panel (NPUAP) revised the pressure injury staging system, which can be found here: www.npuap.org/national-pressure-ulcer-advisory-panel-npuap-announces-a-change-in-terminology-from-pressure-ulcer-to-pressure-injury-and-updates-the-stages-of-pressure-injury. Since then, the NPUAP has received positive feedback regarding the system, and in August, The Joint Commission adopted the new terminology.
The definitions for each type of pressure injury are now:
The new staging system identifies the stages of pressure ulcers as 1 through 4 as well as an unstageable ulcer. These are similar to the codes from the L89 category in ICD-10-CM, however, the system introduces new terms in an attempt to more accurately describe the stages and descriptions of such injuries.
The NPUAP no longer uses the term "pressure ulcer," and has replaced it with "pressure injury," since stage 1 and deep tissue injuries describe intact skin, not open ulcers. The system also introduced the new term DTPI with this update.
Incorporating these changes in ICD-10
CMS has been in discussion with the NPUAP to in-corporate the new terminology, however, these terms are not used in the 2017 ICD-10-CM/PCS code update. The incorporation of the pressure ulcer terminology will be directed by both CMS and The Joint Commission, and NPUAP is currently working to introduce the changes to the code definitions.
According to the NPUAP:
Some documentation requirements for pressure ulcer coding, such as using non-physician documentation for identifying pressure ulcer stages, hasn’t changed from 2016 to 2017. What has changed for 2017 is the requirements for coding the progression of stages.
For ulcers that were present on admission (POA) but healed at the time of discharge, assign the code for the site and stage of the pressure ulcer at the time of admission. Furthermore, if a patient is admitted with a pressure ulcer at one stage and it progresses to a higher stage, two separate codes should be assigned: one code for the site and stage of the ulcer on admission and a second code for the same ulcer site and the highest stage reported during the stay.
These new coding requirements differ greatly from 2016 guidance which required only the highest stage of the pressure ulcer to be reported for pressure ulcers that evolve into a higher stage during the admission.
These new requirements could have an impact on hospital-acquired condition (HAC) reporting, considering stage 3 and stage 4 pressure ulcers with POA indicators of either a N- No or U-Documentation is insufficient are considered to be HACs, and also are classified as major complications or comorbidities.
American Hospital Association Coding Clinic guidance from First Quarter 2009 stated that the National Quality Forum excludes progression of pressure ulcers that were present on admission as a serious reportable event (SRE), also called a "never event." The intent was not to penalize facilities for progression of a pressure ulcer that was POA, as these are difficult conditions and even with the best preventive measures in effect, ulcers may evolve to a higher degree. The revised guidance for 2017, which is necessitating that two codes be used to identify the different stages of a site, feels as if it’s changing the standpoint of whether the pressure ulcer evolution is now an SRE.
The latest Coding Clinic, Third Quarter 2016, has updated guidance for pressure injury terminology. They acknowledge the changes in definition by the NPUAP from pressure ulcer to injury and advise:
For a DTPI, there is an entry in the Alphabetic Index under "injury, deep tissue," with further guidance which states: "meaning pressure ulcer ? see ulcer, pressure, unstageable, by site." Therefore, per Coding Clinic, code a DTPI as an unstageable pressure ulcer by site.
What is in the future for coders?
Can coders expect to see changes in pressure ulcer terminology soon? The most recent Coding Clinic did not give a time frame for updates, thus the potential impact on hospital reimbursement is something we can only speculate on at this point. If a pressure ulcer evolves from a stage 1, 2, 3, or 4 during an inpatient admission, these ulcers could be identified as an HAC and therefore impact the diagnosis-related group.
Editor’s Note:
Commeree is a coding regulatory specialist at HCPro, a division of BLR, in Middleton, Massachusetts. She has many years of experience in the healthcare industry involving coding, auditing, training, and compliance expertise. This article originally appeared on JustCoding, and opinions expressed are that of the author and do not represent HCPro or ACDIS. For questions, contact editor Amanda Tyler at [email protected].
A new sepsis definition: Finding coding compliance at a crossroads
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.
We emphasized that the February 2016 definition of sepsis (Sepsis-3) as a "life-threatening organ dysfunction caused by a dysregulated host response to infection," differed from the terminology of sepsis and severe sepsis that has been embraced by many clinicians, CMS, and ICD-10-CM. We also discussed how provider documentation using the Sepsis-3 terminology eliminates the term "severe sepsis," and discussed that the definition change impacted ICD-10-CM code assignment and compliance.
Definitions and clinical indicators in Sepsis-2 are available at http://tinyurl.com/SepsisTwo, and definitions for Sepsis-3 are available at www.jamasepsis.com. CMS’ definition of sepsis and severe sepsis for the SEP-1 core measure is available at http://tinyurl.com/2017SEP1.
Coding Clinic update
Effective September 23, the American Hospital Association (AHA) Coding Clinic for ICD-10-CM/PCS published advice concerning the documentation and coding of sepsis in light of Sepsis-3. In Coding Clinic, Third Quarter 2016, p. 8, they stated "coders should never assign a code for sepsis based on clinical definition or criteria or clinical signs alone. Code assignment should be based strictly on physician documentation (regardless of the clinical criteria the physician used to arrive at that diagnosis)."
Coding Clinic went on to write (emphasis mine):
In my opinion, this means that Coding Clinic is saying ICD-10-CM still embraces the coding of infections without sepsis, with sepsis but without organ dysfunction, and with sepsis resulting in organ dysfunctions (otherwise known as severe sepsis), if the diagnosis is incorporated by the documenting physician. The AHA further stated that if a physician arrives at a diagnosis of sepsis or severe sepsis using whatever criteria he or she wishes, and then documents these terms in the medical record, the coder is to code it, period, end of story.
Alternatively, while Sepsis-3 states that the word "sepsis" requires the presence of acute organ dysfunction, Coding Clinic states that ICD-10-CM does not recognize this clinical concept. Unless the provider documents "severe sepsis" or associates an acute organ dysfunction to sepsis, a code reflecting this concept, R65.20 (severe sepsis), cannot be assigned. Furthermore, if a provider wishes to diagnose and document the term "sepsis" (without organ dysfunction) using Sepsis-2 or other reasonable criteria, the coder is obligated to code it as such in ICD-10-CM.
Coding Clinic, Fourth Quarter 2016
As we discussed last month, the fiscal year 2017 ICD-10-CM Official Guidelines were amended to state (emphasis mine):
In explaining this new guideline, Coding Clinic, Fourth Quarter 2016, pp. 147?149 stated (emphasis mine):
Coding Clinic went on to highlight that this concept applies only to coding, not the clinical validation that occurs prior to coding. Coding Clinic emphasized that clinical validation is a separate function from the coding process and the clinical skill embraced by CMS and cited in the AHIMA practice brief Clinical Validation: The Next Level of CDI. Access these at http://tinyurl.com/2016AHIMAclinicalvalidation and www.hcpro.com/content/327466.pdf.
Coding Clinic then went on to say that (emphasis mine) "a facility or a payer may require that a physician use a particular clinical definition or set of criteria when establishing a diagnosis, but that is a clinical issue outside the coding system."
While I agree that facilities should standardize clinical definitions for clinical and coding validation purposes, note how Coding Clinic gave tremendous power to a payer to define any clinical term any way they want to. This may differ from that of a duly-licensed physician charged with direct face-to-face patient care responsibilities using the definitions of clinical terms he or she learned in medical school or read in the literature.
As such, while our facilities may implement clinical validation prior to ICD-10-CM code assignment, a payer that is not licensed to practice medicine and has no responsibilities for direct patient care can require a provider or facility to use a completely different clinical definition that serves only one purpose in my mind, and that is to reduce or eliminate payment for care that was properly rendered, diagnosed, documented, and coded. I’m sure that legal battles will ensue, given this caveat written by Coding Clinic.
Solving the problem
In developing a sepsis strategy in light of these Coding Clinics, allow me to remind all of you that there are three environments by which we must consider disease terminology and supporting criteria. One cannot talk about sepsis, severe sepsis, or septic shock unless he or she states what environment they are in. These are:
Therefore, allow me to suggest the following strategy to ensure a balance of compliance with all three of these environments:
1.Standardize the definition and documentation of severe sepsis first. I believe that the Recovery Auditors (RA) are looking for records with sepsis codes that do not have R65.20 or R65.21 (septic shock) as a secondary diagnosis as to deny these codes and their resultant DRGs. In so doing, I believe that the definition of severe sepsis should be negotiated with and standardized by the medical staff, which could incorporate any or all of the following three criteria:
No matter what criteria is used, be sure to coordinate its development and deployment with your quality, clinical documentation integrity, and coding staff so that if a physician documents severe sepsis or septic shock, the SEP-1 algorithm can be implemented.
Also, be sure that physicians explicitly link organ dysfunctions to sepsis, or preferably, use the term "severe sepsis" so that R65.20 is not inadvertently missed by the coders. If a clinical documentation specialist or coder obtains a record supporting R65.20, be sure to notify the SEP-1 manager to determine if it qualifies for the SEP-1 core measure.
2.Develop a facilitywide definition for sepsis without organ dysfunction. As noted last month, many physicians do not believe that organ dysfunction is required to diagnose sepsis. Given that RAs are likely to use Sepsis-3 as a foundation for denying claims, we must have the statements of your internal medicine, critical care, and other physician committees as to what the definition of sepsis is for clinical and coding validation purposes. When it is documented by a provider without evidence of acute organ dysfunction, this statement can be used to rebut the RA’s denials. These will be handy if we are appealing beyond the first level.
3.Remind the RA that the ICD-10-CM guidelines are part of HIPAA and that coding is based on provider documentation. I’m sure that all of our contracts with private payers state that we will comply with federal laws, such as HIPAA. Given that the 2017 ICD-10-CM Official Guidelines state that we are to assign codes based on provider documentation, and not so much on what the RA thinks, and that Coding Clinic, First Quarter 2014, pp. 16?17, states that "the official guidelines are part of the HIPAA code set standards," we don’t want the RAs to violate HIPAA or our contracts with payers. This may require that our hospital attorneys or compliance officers weigh in, given that RAs have been known to deny codes based on provider documentation and want us to do the same.
Summary
Please recognize that this topic is very controversial and that the opinions expressed here are solely my own. I encourage all of us to discuss Sepsis-2, Sepsis-3, SEP-1, the 2017 Official ICD-10-CM Guidelines, and these Coding Clinics with our compliance officers and/or attorneys so that we can best support policies and procedures ensuring complete, precise, and compliant coding of sepsis in light of Sepsis-3. If you have success stories, please share them with me and the editor here at BCCS.
Editor’s note:
This article was part two of a two-part series. You can read part one in BCCS’ October issue. Dr. Kennedy is a general internist and certified coder, specializing in clinical effectiveness, medical informatics, and clinical documentation and coding improvement strategies. Contact him at 615-479-7021 or at [email protected]. Advice given is general. Readers should consult professional counsel for specific legal, ethical, clinical, or coding questions. For any other questions, contact editor Amanda Tyler at [email protected]. Opinions expressed are that of the author and do not necessarily represent HCPro, ACDIS, or any of its subsidiaries.
Has your CDI program shifted its focus for optimal PSI 15 performance?
by Shannon Newell, RHIA, CCS, and AHIMA-approved ICD-10-CM/PCS trainer
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).
Your clinical documentation improvement (CDI) program has likely focused on this measure due to the well-established challenges associated with accurate reporting of procedure-related accidental puncture/lacerations. Given the changes to PSI 15, should your CDI team shift its focus to promote and support accurate data integrity for this measure? Let’s take a look.
A fundamental understanding of patient safety indicator measures
Optimal data integrity for PSIs requires that we have the appropriate clinical documentation and reported ICD-10 codes to accurately reflect the following:
The inputs above?numerator, denominator, risk adjustment?are used to calculate our observed over expected performance. CMS compares our performance to that reported by other hospitals, and our reimbursement may be then impacted if we do not appear to manage patients well.
For example, in the Hospital Acquired Condition Reduction program, if our performance for PSI 90 does not meet established thresholds, then our Medicare fee-for-service reimbursement is reduced by 1% the next CMS fiscal year (October 1?September 30) for every claim we submit.
The new PSI 15?what counts?
The revised measure specifications for PSI 15 have altered the numerator (outcome of interest). The denominator, or cohort?which represents the population at risk?has also undergone a noteworthy change).
The revised numerator and denominator greatly narrow the pool of discharges screened for accidental punctures or lacerations as well as those flagged with outcomes of interest.
From a CDI perspective, the likelihood of incorrectly reporting accidental puncture or laceration for the discharges included in the newly defined measure is greatly diminished.
PSI 15: Are you focused on risk adjustment?
Given that our performance for PSI 15 is assessed using our observed over expected rate of procedure related accidental puncture or lacerations, the CDI team’s focus may be better spent on strengthening the capture of comorbidities relevant to risk adjustment.
The AHRQ risk adjustment methodology looks for multiple comorbidities to calculate the predicted likelihood of accidental punctures/lacerations for each discharge.
The revision to the discharges included in the narrowed cohort has also impacted which comorbidities affect risk adjustment. This makes sense given that these comorbidities must be clinically relevant to the numerator and denominator. The number of comorbid categories has been reduced from 13 to 11. Some of the categories remain the same, some have been deleted, and new ones have been added.
Summary
Keeping abreast of revisions to claims-based measures is an expanded responsibility for today’s CDI program. These measures impact both reimbursement and quality profiles. Positioned with this information, the CDI program can then shift efforts to promote and support clinical documentation capture and accurate reporting of codes associated with areas of the greatest vulnerability and impact.
Editor’s note:
Newell is the director of CDI quality initiatives for Enjoin. She has extensive operational and consulting expertise in coding and clinical documentation improvement, performance improvement, case management, and health information management. You can reach Newell at (704) 931-8537 or [email protected]. Opinions expressed are that of the author and do not represent HCPro or ACDIS.
New clinical criteria definitions in 2017 Official Guidelines up the ante for coders
by Laura Legg, RHIT, CCS, CDIP, and AHIMA-approved ICD-10-CM/PCS trainer
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.
Up the ante means to increase the costs, risks, or considerations involved in taking an action or reaching a conclusion. With the new coding guideline for clinical validation that went into effect October 1, the stakes remain high for the diagnoses documented by the physician to be clearly and consistently demonstrated in the clinical documentation.
It is not that the information was not there before, but now the issue is finally getting attention. When clinical documentation is absent, coders are instructed to query the provider for clarification that the condition was present. But what are we to do if the clinical indicators are not clearly documented? For HIM professionals who deal with payer denials, this has been a haunting issue for a very long time.
The ICD-10-CM Official Guidelines for Coding and Reporting are the foundation from which coders assign codes. Coders need to review the new guidelines in detail to understand the changes and implications for their facilities.
The Centers for Disease Control and Prevention published these new guidelines which can be read in their entirety here: www.cdc.gov/nchs/data/icd/10cmguidelines_2017_final.pdf.
Taking a closer look
The coding guideline for section A.19 (code assignment and clinical criteria) has been labeled as controversial and, at this point, we have more questions than answers. Denials issued by payers due to the absence, or perceived absence, of clinical indicators by which the payer lowers the DRG is now being called DRG downgrading and it’s getting attention.
The code assignment and clinical criteria states:
Physicians and other providers document a patient’s condition based on past experience and what the clinician learned in medical school, which often differs from clinician to clinician. When you put a patient in front of a group of clinicians you will most likely get differing documentation. So how do we fix that?
The diagnosis of sepsis is a good example. There does not appear to be a universally accepted and consistently applied definition for the condition of sepsis.
In a patient record with the principal diagnosis code of sepsis, followed by the code for the localized infection, pneumonia, a payer denial could occur.
Payer denials often deny the sepsis diagnosis code stating that "the diagnosis of sepsis was not supported by the clinical evidence. Therefore, as a result of this review, the diagnosis code A41.9 [sepsis, unspecified organism] has been removed and the principal diagnosis re-sequenced to code J18.9 [pneumonia, unspecified organism] for pneumonia and to the lower paying DRG 193." This is now being referred to as a DRG downgrade. DRG downgrades can occur for different reasons including both DRG coding changes and clinical validation downgrades.
What is a coder to do?
What is a coder to do when a physician documents a diagnosis that may not be supported by the clinical circumstances reflected in the patient’s chart? Facilities and coding teams should develop guidance and be sure they fully understand the content and the impact of this coding guideline to coding practices.
Remember the section that reads: "the assignment of a diagnosis code is based on the provider’s diagnostic statement that the condition exists. The provider’s statement that the patient has a particular condition is sufficient."
This represents a catch-22. If the diagnosis is not clinically validated, both recovery auditors (RA), as well as commercial insurance auditors, are going to deny the claim. On the other hand, if coders or the facility decide not to report the diagnosis, they are in violation of the coding guidelines, which is also a major problem.
AHIMA’s 2016 Clinical Documentation Toolkit offers this advice:
The toolkit is available here: http://bok.ahima.org/PdfView?oid=301829.
Increasing clinical documentation
As the healthcare industry experiences an increased number of external audits, both federal and private, the need to up the ante on clinical documentation has become essential. The answer is not to let this guidance prompt lazy documentation, which has far reaching consequences, but to use it as a catalyst for improvement.
The goal of any clinical documentation improvement (CDI) program is to ensure a complete and accurate patient record, and this cannot be done without the presence of documentation supporting the clinical indicators and clear and consistent documentation regarding the condition. The provider’s documentation of their full thought process will accomplish this. If medical staff can come together and agree upon a definition for a certain condition, they can begin the process of being consistent with how the description is presented in the patient record.
CDI specialists and coders should not use the new guideline as an excuse not to query. Coders are not clinicians and, therefore, should not be expected to evaluate clinical criteria. Coding and CDI were separate functions, but, as audits from outside organizations expand, there is more emphasis on correct coding, DRG assignment, and the use of clinical criteria to support the reported codes, which means these entities need to work together.
The American Hospital Association’s Coding Clinic for ICD-10 instructs coders not to use background clinical information contained in their responses for code assignment. This information is only provided so the coders can make a judgment to query where there is incomplete documentation. Coders and CDI staff should review all chart documentation and data, and query when necessary to clarify inconsistencies in physician documentation.
Query the provi
Internal auditing strategies for ongoing ICD-10 success
Editor’s note: This article was modified from HCPro’s latest long-term care title, ICD-10 Compliance: Process Improvement and Maintenance for Long-Term Care, written by Maureen McCarthy, BS, RN, RAC-MT, and Kristin Breese, BSN, BSed, RN, RAC-MT. The complete book helps facilitate ongoing ICD-10 success by arming SNF readers with information and strategies that target the preparation, implementation, and maintenance phases of the fast-approaching coding transition. For more information or to order, call customer service at 800-650-6787 or visit www.hcmarketplace.com.
With the October 1 implementation date of ICD-10 now on a fast track to fruition?and no further delays in sight?even the most committed holdouts in the provider community have kicked off initiatives to ensure staff, outside business partners, and workflows can withstand the major coding transition.
To ensure that preparations made over the past months (or years) ultimately pay off, SNFs should start laying the groundwork for regular facility-wide audits of ICD-10 systems in the aftermath of implementation?a proactive approach that can help providers verify the strength of ongoing transition efforts and catch any snags before they disrupt essential facility processes.
Thus, although the word "audit" can provoke fear and anxiety in providers?often connoting scrutiny and penalties when administered by Medicare contractors?facilities can head off these unsavory external audits, or at the very least reduce negative outcomes, by conducting their own internal varieties.
In a broader sense, frequent self-audits can promote overall business vitality by facilitating the development and maintenance of sustainable processes across the facility, particularly in the face of the impending overhaul to coding methodology and practice.
The scope of self-audits
The Office of Inspector General (OIG) considers ongoing monitoring and evaluation important elements of a healthcare organization’s compliance program and identifies two overarching types of reviews:
1.Standards and procedures reviews, which measure whether internal standards are current and complete, or are in need of an update to reflect regulatory changes
2.Claims submission audits, which gauge whether coding, billing, and documentation are in compliance with payer and government contractors, as well as whether services performed are reasonable and support medical necessity
The OIG states that self-audits, which generally fall into the second category of reviews, can accomplish an array of verification processes. More specifically, the agency explains that these audits can be used to determine whether:
The baseline audit
SNFs should launch a baseline audit after the first three months of ICD-10 implementation. This initial evaluation will help providers identify areas that need improvement or education. To shape baseline (and subsequent) audits, facilities should consider the following list, which identifies key aspects of major operational areas the ICD-10 transition is likely to affect:
1.Documentation
2.Coding/billing in the electronic health record system
3.Guidelines
4.Education
5.Strategic considerations
Subsequent audits
Once SNFs have completed their baseline audits, they should analyze the outcomes to develop an auditing compliance plan, which can function as staffs’ blueprint for future documentation, coding, and billing.
The ICD-10 task force, or transition team, should appoint a post-ICD-10 committee to review initial implementation results, evaluate success against established criteria, and identify what works and doesn’t work, especially in the revenue cycle, health information management, and IT realms.
Prior to the October 1 kickoff, this committee should determine which measures will be tracked and collect related preliminary data.
Following the go-live date, this committee?and the facility at large?must be on the lookout for significant post-implementation issues, including claims denials and rejections or coding backlogs. The committee must quickly identify such issues, create feedback loops, and follow the established solution path to remediation?a task that’s best facilitated by routine auditing of both claims and supportive documentation in a patient’s medical record.
Facilities should track all ICD-10 submissions and receipts for 3?6 months after the transition. Quality assurance monitoring should focus on ensuring proper receipt of ICD-10 codes by vendors and payers. Providers should also be sure to address all communications from these sources, as well as trading partners and CMS.
Key takeaways
Routine review of ICD-10 coding will soon become an essential function of all facilities’ quality monitoring systems and resulting performance improvement plans. Auditing documentation for sufficient data to support specificity in ICD-10 diagnosis coding should begin 2?3 months prior to the transition and continue well after October 1. Conducting ongoing auditing is crucial to update or solidify processes that underlie, facilitate, and support ICD-10 coding and claim submission, thereby ensuring a hassle-free conversion to the new system.
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Now that health insurance reform has passed, good medical practice management is more important than ever. With a projected increased workload for the same or perhaps even less pay, how well you manage things may well be the key to keeping your practice
afloat financially.
It’s a true shame that primary care physicians have to spend so much time and energy on management just to get paid. I’m not a physician, but before becoming a wealth management consultant, I was a medical sales rep. I have nothing but respect for doctors, especially for the primary care doctors who are on health care’s front lines.
The sad thing is that the profession as a whole isn’t getting the respector the reimbursementsit deserves, and in my opinion the recently-passed reform legislation isn’t going to help. With that in mind, I’ve been doing some research into practice management and have found some good tips from Physicians Practice and ModernMedicine, two online magazines for physicians.
As a physician, you can qualify for $ 44,000 over 5 years under Medicare or $ 63,750 over 6 years through Medicaid for making your practice a meaningful user of electronic health care records (EHRs). But you have to be careful because of the hefty, HIPAA-mandated fines for not keeping private information secure. Be sure to do a lot of research before choosing an electronic medical record system to adopt for your practice.
Do what you can to keep staff turnover low. Use management strategies like small rewards, making sure your staff are all well trained, and doing your best to have the right person in the right job. You may even save money by paying staff a bit more, considering that it can cost your practice anywhere from $ 3 to $ 4 thousand dollars every time someone quits.
The recession is making it even more important to collect payment from patients up front. Obviously, you want to help people who are struggling because of the economy. But to keep your practice sound financially you’re going to need to manage the balance between helping and getting paid what your work is worth. And rememberyour staff is counting on you for their salaries, too.
Be sure to automate everything you can. An automated patient-reminder system, for example, can save you on staff costs. Claims-scrubbing software can catch mistakes in billing that could lead to denied claims and thus increase your income.
Take time to learn about upcoming changes in coding regulations. There are more than 200 changes in 2010 that you should be aware of. Again, we all know that health insurers and the government will seize on any reason to deny your claims. You certainly don’t need to help them!
I still think it’s sad that primary care doctors have to spend so much time managing their practices, sometimes at the expense of patient care. In an ideal world, primary care physicians in particular would be left alone to do the work theyve spent years and over $ 100K training to do.
But since medical practice management is part of the jobif only to learn enough so you can hire and supervise an expert managerthe best thing is to learn everything you need to learn and apply it so you can keep your practice profitable. I hope these tips help!
Jen Gilbert is a physician wealth management consultant and Internet entrepreneur. She helps primary care physicians achieve their financial goals through education, information, and motivation. Previously a highly successful medical sales representative, Jen founded her consulting business to help busy physicians position themselves for a secure financial future. For more information, visit her website at www.physicianwealthstrategies.net.
Intraday trading brings together perspectives from any different time frames into a single arena. Sometimes it is hard to make sense of why buyers and sellers react so strongly at certain price levels and not at others. How can you quickly and easily organize the information from different time frames to shape your trading decisions?
One way to to frame your trading environment is to look at multiple time frames and find patterns and price levels that indicate support and resistance levels in the past. We cannot know with any certainty why a price level became support or resistance. The good news is that we don’t need to know why, only that it DID!.
The reasons why support and resistance occurred fade pretty quickly in time. All that remains, like footsteps in the snow, is the price record maintained on charts for all to see. The places where price turned and reversed will begin to take on a power in the minds of all chart readers and will begin to influence their decisions to buy and sell, to preserve profits or anticipate reversals.
This is why congestion areas begin to form around certain price levels.
In the same way that we should not be supposed to see traffic forming around major cities, we should expect choppy price behavior around previous support and resistance levels, and near the 50 day and 200 day moving averages, the two most popular moving averages.
Once you have identified the obvious support and resistance levels, treat prices greater than the congestion area as “Green zones” where you would not be surprised to see price move swiftly up.
Identify the congestion areas as “Yellow zones” where choppy behavior is the norm and where you do not have a particular edge unless you are a master tape reader.
Red zones are open price areas below congestion, where price can be expected to fall quickly once it breaks out of congestion.
In the Red and Green zones, which are really mirror images of each other, you want to be positioned to go with the path of least resistance. There’s not a lot of time to wonder what to do when price is here. Don’t chase price, but certainly take advantage of limit orders to pull you into good positions.
In the Yellow zone you should never chase, and always require a visible 2:1 reward to risk ratio inside the yellow zone to justify your entry. Don’t expect price to break out either, since congestion zones we expect price to be choppy and for breakouts to be false.
Framing your trading decisions in terms of these 3 color codes can definitely help you make proper decisions in the heat of the moment.
Ken Long, Chief of Research, Tortoise Capital Management
finance: http://www.tortoisecapital.com
essays: http://kansasreflections.wordpress.com
