Archive for November, 2011

November 23, 2011

M1308, the question that keeps on giving …

Several questions in CMS’s 3rd quarter Q&As deal with pressure ulcers and M1308.

The highlights (in my words, not CMS’s!):

  • Should a muscle flap be reported in M1308 as a current pressure ulcer? No. It is a surgical wound (as are skin advancement flap, or rotational flap)
  • If the pressure ulcer has a skin graft, how is it treated? Not as a surgical wound but as unstageable until it heals, then Stage III or IV.
  • How do you report a Stage III that is closing to the point of a pinpoint? As a Stage III …

Find CMS’s full answers here.

November 21, 2011

CMS will enforce 5010 standards in April

The Centers for Medicare & Medicaid Services’ Office of E-Health Standards and Services (OESS) will not initiate enforcement action with respect to any HIPAA covered entity non-compliant with the ASC X12 Version 5010 (Version 5010), NCPDP Telecom D.0 (NCPDP D.0) and NCPDP Medicaid Subrogation 3.0 (NCPDP 3.0) standards until 90 days after their January 1, 2012 compliance date, or until March 31, 2012.

The compliance date for implementation of these updated standards remains January 1, 2012.

Look at the Latest News page of the ICD-10 website.

November 15, 2011

ABN changes must be done by Jan. 1

Don’t forget that CMS will require use of its revised ABN (form CMS-R-131) in January. This will replace the 2008 form.

The ABN is used by all providers, practitioners, and suppliers paid under Medicare Part B, as well as hospice providers and religious non-medical healthcare institutions (RNHCIs) paid exclusively under Part A.

Medicare link to new ABN

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November 14, 2011

Jan. 1 M0090 date is the end for case-mix hypertension

CMS has clarified that payment changes relative to the removal of the hypertension codes will be effective with M0090 dates of 1/1/2012.

“Beginning with M0090 dates of January 1, 2012, 401.1 Benign essential hypertension codes and 401.9 Unspecified essential hypertension are removed from the HH PPS case-mix system. Specifically, 401.1 and 401.9 diagnosis codes will no longer result in additional points when computing the HIPPS codes”

Providers should not change the codes they use for hypertension unless they have been coding the 401 codes in error. Changing the codes just to get points is upcoding and we certainly do not want to prove CMS correct about case mix creep. You can be sure that they will be watching for trends in hypertension coding as a result of the case mix change.

Remember hypertension with chronic kidney disease (585) or renal sclerosis (587) changes the hypertension code to the 403 category. There is a presumed relationship between CKD and HTN with HTN causing the CKD.

However, a relationship between heart disease and HTN cannot be presumed. The physician must either state (e.g., heart failure due to hypertension) or imply the relationship (e.g., hypertensive heart disease).

Even if you do not have the information to be able to change the hypertension code to some other category besides 401, do not despair! Remember that hypertension and heart disease are together in Table 4. Even if you do not earn points with the hypertension codes, think how many of your patients with 401 codes also have codes from the 414 category (coronary atherosclerosis and chronic ischemia), 410 (acute myocardial infarction) and 428 (heart failure). Those codes are case mix, too, so you will not be losing any points!

Grouper information!

November 10, 2011

Comment on chronic wound issues

Public comment is open until Dec. 9 regarding chronic wounds. In the past, CMS has said that plasma products used for wound healing is not a reasonable and necessary treatment for the treatment of chronic non-healing wounds. (NCD 270.3)

CMS is now reconsidering NCD 270.3 to determine whether the policy should change regarding the use of autologous platelet rich gel in patients with chronic non-healing pressure ulcers, venous ulcers, and diabetic foot ulcers.

CMS has defined a chronic wound as one in which the healing process has failed to progress properly and the wound persists for longer than 30 days.

Read the full statement from CMS and make a public comment.