Archive for September, 2010

September 30, 2010

Watch your “with”

Code changes happen tomorrow … doesn’t Oct. 1 always sneak up on us?

To look at my overview of the changes, just go to my Musings-of-a-Codeaholic page!

Along with code changes have come some guideline changes, and I want to remind everyone what CMS is now saying about “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 word “with” in the alphabetic index is sequenced immediately following

the main term, not in alphabetical order.”

The bolded text is the part that takes effect Oct. 1 This should eliminate a lot of confusion over relationships with this important preposition.

Looking for guidelines? Look no further!

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September 28, 2010

Straight up surgical wound guidance

I get many questions on venous devices and whether they are current surgical wound … Here is CMS’s official guidance.

From CMS: An implanted venous access device is considered a current surgical wound as long as it is implanted in the patient’s body. When first implanted, the incision is the surgical wound. The assessing clinician will follow the 12/09 WOCN guidance to determine the healing status of the incision. Once it is fully epithelialized, the site due to the implanted device will remain a current surgical wound with a status of “Newly epithelialized” for as long as it is present in the patient’s body, unless it later develops complications.

Looking for the official guidance? Look at CMS’s OASIS Q&A, Category 4b, Q105.3.

September 23, 2010

You can use new codes Sept. 26-29 … read on

Every year, we worry about new codes, but we start to panic about when to start billilng with them … it’s not as simple as Oct. 1!

I’ve been corresponding with CMS on this issue, and here is the current, correct, information.

I started by simply asking if the effective date for using new and changed codes is based on M0090 or based on episode start dates?

  • In the past, it was based on episode start dates.
  • Last year, CMS announced via the home care forum that the effective date is based on M0090.

An expert at CMS stated that the “HH Grouper validates ICD-9 codes based on the M0090 date.” He added that there is a billing instruction (only one): That the diagnosis codes on the RAP match the codes in M1020 and M1022.

Actually, he typed in “M0230 and M0240,” so I followed up asking if the manual had been updated to OASIS-C. He said it would be shortly.

What about episodes that span Oct. 1?

CMS said that Medicare “allows either year’s Dx codes on RAPs or claims that span 10/1.” The reason this can happen is that there is a documented bypass for our type of billing (it you want to read the regs, just click below and go to p.27). The bypass also means that 2011 codes can be used Sept. 26-Sept. 29!

Here is the short of the bypass, and a link to the full document:

The bypass is documented in the IOCE specs, on p.27:

7) Bypass diagnosis edits (1-5) for bill types 32x and 33x (HHA) &12x (inpt/B) if From date is before October 1 and Through date is on or after October 1. And for bill types 322 & 332 if From date is between 9/26 and 9/30, inclusive.

http://www.cms.gov/OutpatientCodeEdit/Downloads/Attachment_A_IOCE_Specifications_Document_V113.pdf

Still looking for new codes education! Order a CD of my 90-minute education that dealt with coding, RTP, billing, and trend issues to be aware of!

September 21, 2010

Correct pressure ulcer terminology will stop errors in M1320

Correct documentation, and wording in that documentation, are crucial to correct OASIS and coding. Pressure ulcers have very specific wordings, and using the incorrect phrase with a certain stage ulcer can result in rejection or validation errors as you electronically submit your records.

Let’s say this is your documentation:
M1308: a. Stage II, Number present: 2
M1320: 1- Fully Granulating
There is a note from the nurse that the ulcer is not “not healing,” so 03 on M1320 is ruled out by the agency.
Submitting this will result in a validation error on M1320. Why? Because Stage II pressure ulcers do not granulate. According to WOCN guidelines, if no granulation tissue is present, then the ulcer is not healing. If the RN is, indeed, seeing red beefy tissue (granulation) then the ulcer is likely to be at least a Stage III. OASIS does not allow any answer other than ‘not healing’ on Stage IIs.
Watch the WOCN website (linked on this blog) for definitions and pressure ulcer policy … and make sure to read your OASIS manual well for guidance!

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September 19, 2010

CMS updates home health quality manuals

A new week, and CMS has some updates to some home-health focused manuals on its website:

The new Process Based Quality Improvement (PBQI) Manual can be downloaded at www.cms.gov/HomeHealthQualityInits/15_PBQIProcessMeasures.asp.

The revised, updated Outcome Based Quality Improvement (OBQI) Manual can be downloaded at www.cms.gov/HomeHealthQualityInits/16_HHQIOASISOBQI.asp.

The revised, updated Outcome Based Quality Management (OBQM) Manual can be downloaded at www.cms.gov/HomeHealthQualityInits/18_HHQIOASISOBQM.asp.

Also, as a reminder, the OASIS-C Guidance Manual and recently released errata can be downloaded at www.cms.gov/HomeHealthQualityInits/14_HHQIOASISUserManual.asp.

September 14, 2010

Always code Stage 3 and 4 pressure ulcers

Here is subject I field many, many questions on: the coding of stage 3 and 4 pressure ulcers.

Question: I recently read that closed pressure ulcers, regardless of stage, should not be coded. Is this true? I thought all Stage 3 & 4 closed pressure ulcers should still be coded.

Lisa says: Stage 3 and 4 pressure ulcers are never considered healed, but they can close. Because there is a strong risk that they will open again, they should be coded in a patient’s episode. If they are open ulcers, they would require much care, so they probably would be listed higher in your coding sequence, but the sequence will always depend on the seriousness of conditions, not just that these are difficult pressure ulcers. If they are closed pressure ulcers, you would probably code them lower, based on the time of care expended vs. the patient’s other needs.

Remember (and never forget) that closed stage 3s and 4s always require active intervention, including assessment and pressure ulcer risk interventions. The tissues lost are replaced by granulation tissue and they are always at risk. Because they should be addressed in the POC, they should be coded.


As for Stage 1 and 2 pressure ulcers: Code them when they are open. When they are closed and evidence of them is gone, they are considered healed, and they should not be coded.

In any case, watch the OASIS: There are nine items that deal with pressure ulcer assessment; be sure to watch all of them.

Looking for references on pressure ulcers? This is the WOCN’s position statement, which is considered official guidance.

September 13, 2010

Dialysis shunts are surgical wounds

CMS has been answering questions regarding dialysis shunts and surgical wound rules. In short, the dialysis shunt is a surgical wound, but the 30 day rule does not apply. It is considered a surgical wound as long as it is in place. Read below for the official information:

Question: M1342 Surgical Wound –implanted venous device: I am confused by one of the CMS OASIS Q&As. The answer to Q105.3 states that an implanted venous device is considered a surgical wound until it has been epithelialized completed for 30 days at which time it becomes a scar. The next sentence of the answer says that the site is considered a surgical wound as long as the device is in place. Can you clarify this?

Answer from CMS: An implanted venous access device is considered a current surgical wound as long as it is implanted in the patient’s body.

When first implanted, the incision is the surgical wound. The assessing clinician will follow the 12/09 WOCN guidance to determine the healing status of the incision. Once it is fully epithelialized, the site due to the implanted device will remain a current surgical wound with a status of “Newly epithelialized” for as long as it is present in the patient’s body, unless it later develops complications. This guidance clarifies and supersedes CMS OASIS Q&A Category 4b, Q105.3.

Click here to do some searches on this question and others.

September 9, 2010

Rehab facility status is key to answering M1010, M1012, M1016

Are rehabilitation facilities considered inpatient settings? That is the key to answering M1010, M1012 and M1016 correctly if you patient comes from such a facility.

Let’s say a patient is discharged from a hospital on Sept. 1 and goes to a rehab facility and isn’t discharged from their until Sept 24. SOC is Sept. 25.

How should M1010 (inpatient diagnosis), M1012 (inpatient procedures) and M1016 (regimen change) be answered?

The key is to remember that a rehab facility is an inpatient facility (see M1000), so the diagnoses treated there would pertain to M1010 and M1016. Procedures would not be performed at a rehab facility, so M1012 wouldn’t apply.

September 8, 2010

Non-PECOS physician claims will be processed before Jan. 1

This is a PECOS update from TAHC

PECOS Update

The Centers for Medicare & Medicaid Services (CMS) has issued Transmittal 765 regarding expansion of claims editing to meet the July, 6 PECOS requirement. The transmittal states that the claims editing will be implemented in two phases. The initial phase begins October 1, 2010, and the second phase is set to begin on or after January 1, 2011.  These edits are being put into place to begin verification of physician’s name and NPI number as they appear on the “Medicare Ordering Referring File.” Agencies that bill the Medicare program must ensure that claims contain accurate information from the “Medicare Ordering Referring File.” The following describes the two phases and if you wish to read Transmittal 765, please click here.

Phase 1 (October 1, 2010 –December 31, 2010) – When a claim is received, CMS will determine if the attending physician is required for the billed service. If the attending physician’s NPI is on the claim, Medicare will verify that the attending physician is on the national PECOS file. If the attending physician NPI is not on the national PECOS file during Phase 1, the claim will continue to process but a message will be included on the remittance advice notifying the billing provider that claims may not be paid in the future if the attending physician is not enrolled in Medicare or if the attending physician is not of the specialty eligible to be an attending physician for HHA services.

Phase 2 (On or after January 1, 2011) – As stated above, Medicare will determine if the attending physician’s NPI is required for the billed service. If the billed service requires an attending physician and the attending physician’s NPI is not on the claim, the claim will not be paid. If the attending physician’s NPI is on the claim, Medicare will also verify that the attending physician is on the national PECOS file. If the attending physician is on the PECOS file, but not as a specialty eligible to be an attending physician, the claim, during Phase 2, will not be paid.

September 7, 2010

The straight guidance on M1024

I receive many, many questions on M1024, OASIS’s payment question. I recently had this one:
Question: I am trying to get some clarification on when to fill in M1024 if a V code is used in place of a case mix. It was my understanding that you would fill in M1024 if a V code was used in the primary spot for an acute or resolved condition or a DM, Neuro or Skin 1 code. You would not fill in M1024 for a V code in the primary spot if the condition was still active and going to be listed in the secondary spots, other than the DM, Neuro or Skin 1 code.
Also what about V codes in the secondary spots, do we need to fill in M1024?

Lisa says: Remember that M1024 was created as a payment slot for when V codes replace diagnosis codes. This way, the patient’s condition is fully represented. M1020 and M1022 deal with active diagnoses. M1024 is mainly for resolved diagnoses, but CMS has made a few exceptions to this general rule.

The OASIS manual offers a lot of guidance on when to use M1024, and it boils down to these situations:
• When a V code replaces a resolved case mix condition that is the reason the V code is placed in M1020 or M1022.
• When a V code replaces a fracture. Fractures are acute diagnoses, so they are not allowed in M1020 and M1022, per official coding guidelines. We can place them in M1024.
• Use M1024 when a V code in M1020 replaces a diagnosis from the Diabetes, Skin 1 and Neuro 1 case mix categories, regardless of active or resolved status. These three case mix categories are the only ones that receive different case mix points based on whether they are coded primary or secondary. CMS has allowed coding of active conditions in M1024 in these very specific conditions. Still code these three categories in M1022 when active.

If a diagnosis code is active, and therefore eligible for coding in M1022, it cannot be listed in any M1024 slot, with the exception of the three categories listed above.

Yes, you should fill out M1024 in secondary slots, as long as the etiology is for a different underlying, resolved condition than a diagnosis listed in another M1024 slot. For example, if resolved breast cancer is the reason for V codes in M1020 and M1022, don’t put 174.9, the breast cancer code, in both M1024 slots. You have already represented the disease in the M1024 slot across from M1020. Don’t put it across from an M1022 slot, as well. If you code multiple V codes and each has a different etiology, certainly list each across from the appropriate V code. Only case mix codes are eligible for M1024, but there is more than case mix at play: risk adjustment can also be recognized in M1024 slot.

Remember: Only case mix codes are eligible for M1024.

Keep in mind this compliance issue: All M1024 and resolved conditions must be on the plan of care, even though M1024 is not part of the claim. There is no “official” or “right” place to put these conditions, but Locator 21 is an often-used documentation spot.

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