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February 17, 2012

AHIMA weighs in on ICD-10

A statement from AHIMA:

 

AHIMA members,

This week’s announcement from Health and Human Services (HHS) to pursue a delay was indeed a disappointment for all of us who have worked so hard to support the implementation of ICD-10. This surprise announcement reaffirms that AHIMA’s leadership on ICD-10 has never been more important. AHIMA is committed to advocating for ICD-10 to be implemented as soon as possible.

In the coming hours, days and weeks, we will be reaching out to those making the decisions to educate them about the importance of ICD-10 and encourage them to keep this delay as short as possible. You and I know the benefits to implementing ICD-10 are enormous—it will make our healthcare system more efficient and cost effective, and the richer data provided by ICD-10 will help improve the quality of healthcare for all patients. We also know that many of you have been working in good faith to prepare for this deadline.

We are meeting today to discuss short- and long-term strategies for addressing this challenge and will be calling on you for your support. In the meantime, we encourage you to maintain your vigilance in preparation for ICD-10 and to offer your expertise to others. As you know, AHIMA is here to help as the industry makes this change.

Thank you for your continued commitment to advance HIM and your dedication to AHIMA. We will keep you up to date as we move forward.

Lynne Thomas Gordon, MBA, RHIA, FACHE, AHIMA Chief Executive Officer

 

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February 17, 2012

Straight to ICD-11?

Don’t you think its funny that the webpage notices are titled “ICD-10-CM is coming Oct 1, 2013″ with byline “It’s closer than it seems” followed by “HHS Announces Intent to Delay ICD-10-CM”?

So what’s my theory on why CMS “intends” to delay implementation? I have a couple.

First, physicians are raising a big ruckus about ICD-10. I can understand why when Medicare cuts their payment by 27% and then requires compliance with something this huge. So is CMS listening? I think it boils down to it’s an election year and, lo and behold, President Obama decides to reduce regulatory burden by delaying a regulation that has been finalized since 2009. My opinion is that continuing to use an antiquated system like ICD-9-CM increases regulatory burden. Health plans, hospital systems and other payors and providers, including HHS, have spent millions of dollars readying for ICD-10-CM. A delay now will increase the money spent and the time spent.

Second, the United States has long been behind the rest of the world in coding. A friend told me once that the folks at the World Health Organization (WHO) make fun of us because we are so far behind. Those nations now using ICD-10 are getting ready for a move to ICD-11 October 1, 2015. Does that date seem familiar? Just maybe we are going to switch gears, skip ICD-10-CM and we’ll keep up with the rest of the world with ICD-11-CM in our near future, i.e., Oct 1, 2015.

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February 16, 2012

HHS: Some entities will have ICD-10 delays

A news release issued by HHS today:

As part of President Obama’s commitment to reducing regulatory burden, Health and Human Services Secretary Kathleen G. Sebelius today announced that HHS will initiate a process to postpone the date by which certain health care entities have to comply with International Classification of Diseases, 10th Edition diagnosis and procedure codes (ICD-10).

The final rule adopting ICD-10 as a standard was published in January 2009 and set a compliance date of October 1, 2013 – a delay of two years from the compliance date initially specified in the 2008 proposed rule.  HHS will announce a new compliance date moving forward.

“ICD-10 codes are important to many positive improvements in our health care system,” said HHS Secretary Kathleen Sebelius.  “We have heard from many in the provider community who have concerns about the administrative burdens they face in the years ahead.  We are committing to work with the provider community to reexamine the pace at which HHS and the nation implement these important improvements to our health care system.”

ICD-10 codes provide more robust and specific data that will help improve patient care and enable the exchange of our health care data with that of the rest of the world that has long been using ICD-10.  Entities covered under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) will be required to use the ICD-10 diagnostic and procedure codes.

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February 15, 2012

Delay in ICD-10?

The CMS acting director testified Tuesday that the agency may consider delaying ICD-10.

Here are several links to stories:

The Hill: http://thehill.com/blogs/healthwatch/medicare/210525-medicare-chief-vows-to-delay-burdensome-rules-on-doctors-

Government Health IT: http://www.govhealthit.com/blog/tavenner-really-trying-delay-icd-10

 

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February 8, 2012

RAC demonstration reviews begin after June 1

After a six-month delay, CMS just announced that the Recovery Audit Prepayment Review will move forward after June 1.

The review (a demonstration project) will allow Medicare Recovery Auditors (RACs) to review claims before they are paid to ensure that the provider complied with all Medicare payment rules. The RACs will conduct prepayment reviews on certain types of claims that historically result in high rates of improper payments.

The demonstration is part of CMS’s crackdown on waste and fraud.

The reviews will focus on seven states with high populations of fraud- and error-prone providers (FL, CA, MI, TX, NY, LA, IL) and four states with high claims volumes of short inpatient hospital stays (PA, OH, NC, MO).

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February 7, 2012

Don’t forget the buddies!

The coding world got upset during the Open Door Forum not too long ago. The CMS spokesperson was talking about the removal of data validity flags on etiology/manifestation pairs and said the grouper would capture the points if the manifestation was coded anywhere under the etiology.

Someone then asked for clarification and again he said that the manifestation did not have to be coded directly after the etiology (not an exact quote). The spokesperson was not speaking of the coding guidelines, but of the grouper and data validity flags. CMS is not overriding the coding guidelines and making a new rule just for us!

Coding guidelines are clear, and here’s a quote from Appendix D section 6 (December 2011) of the OASIS-C Guidance Manual from CMS:
“Criteria associated with etiology/manifestation pairs coding are listed below:

The etiology code is the underlying disease and must be sequenced first, before the code for a related manifestation. When a diagnosis is under consideration as an etiology diagnosis, the HHA is expected to ensure that a valid manifestation code is sequenced immediately following the assignment of the etiology code.”

So, don’t go breaking up your buddy codes!!

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February 6, 2012

AHRQ database of clinical practice guidelines are at your fingertips

This webpage has a top-level directory of all of the practice guidelines. Ones that interest home health the most:

Pressure ulcer prevention

Pain management, including cancer and acute pain

Urinary incontinence

Heart failure and cardiac rehabilitation

Take a look at your agency’s policies and see if things can be improved!

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February 3, 2012

More than checking a box

I’m working on a lot of audits—responding to ADRs and requests for redeterminations these days—both probe edits and ZPICs. One of the many things I’m noticing about documentation is the non-support of homebound status.

We check boxes such as “considerable and taxing effort” and “requires assistive device” but there is little documentation to support WHY there is a considerable and taxing effort and WHY an assistive device is required. Homebound is based on the patient’s illness or injury that is creating a taxing effort to leave home.

The Medicare Benefit Policy Manual Chapter 7 30.1.1 states: “Generally speaking, a patient will be considered to be homebound if they have a condition due to an illness or injury that restricts their ability to leave their place of residence except with the aid of: supportive devices such as crutches, canes, wheelchairs, and walkers; the use of special transportation; or the assistance of another person; or if leaving home is medically contraindicated. [emphasis added] The condition that creates the homebound status needs to be clearly documented.”

Don’t just check a box and move on!! If you need any assist in responding to probe edits or ZPIC redeterminations, we are standing by to assist. The process takes time and after preparing the documentation for you we can provide targeted education to your staff to get you on the right path.

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January 30, 2012

ICD-10 training in Vegas!

Come to my ICD-10 training in Las Vegas on March 5-6 ..

More details to come!

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January 26, 2012

Watch for Palmetto and other probe edits … We can help!

Probe edits are underway from Palmetto with other MACs joining in soon. It is important to follow instructions from your MAC and respond with complete copies of charts.

Selman-Holman & Associates, LLC has been assisting clients with this process for many years and we have been heavily involved in responding to the new round of ADRs and probe edits. Your agency is at greater risk if you 1) have a long length of stay (LOS); 2)  have Medicare beneficiaries under the age of 65; and 3) have frequencies of 1w9.

Call us for assistance if you receive a probe notification letter or ADRs. We have an expert team of home health care documentation and coverage experts standing by!

Message from Palmetto:

From: Jurisdiction 11 Home Health and Hospice

Alert: Medical Additional Documentation Requests (ADRs)

Palmetto GBA recently changed the process for mailing medical Additional Documentation Requests (ADRs).  Previously, medical ADRs were mailed in yellow envelopes. ADRs are now mailed in white Palmetto GBA envelopes. It is possible that a provider may receive an ADR request prior to receiving their probe notification letter.

If you receive an ADR, it is important that you respond promptly.

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