HCCA Compliance Institute 2012

Can you believe it’s that time of the year already?!  We are looking forward to HCCA Compliance Institute in Las Vegas this month.  Stop by our booth (#415) and enter our drawing to win a half day of onsite education for your coders, physicians and/or HIM team.

See you there!!

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HHS Proposes One – Year Delay in ICD-10 Implementation

The latest news from CMS…

The Department of Health and Human Services (HHS) today announced a proposed rule that would delay, from October 1, 2013 to October 1, 2014, the compliance date for the International Classification of Diseases, 10th Edition diagnosis and   procedure codes (ICD-10).

The ICD-10 compliance date change is part of a proposed rule that would adopt a standard for a unique health plan identifier (HPID), adopt a data element that would serve as an “other entity” identifier (OEID), and add a National Provider Identifier (NPI) requirement.   The proposed rule was developed by the Office of E-Health Standards and Services (OESS) as part of its ongoing role, delegated by HHS, to establish adopt standards for electronic health care transactions under the Health Insurance Portability and Accountability Act of 1996 (HIPAA).   OESS is part of the Centers for Medicare & Medicaid Services (CMS).

Background

On January 16, 2009, HHS published a final rule to adopt ICD-10 as the HIPAA standard code sets to replace the previously adopted ICD–9–codes for diagnosis and procedure codes (see HIPAA Administrative Simplification;  Modifications to Medical Data Code Set Standards to Adopt ICD-10-CM and ICD-10-PCS,  74 FR 3328). The compliance date set by the final rule was October 1, 2013.

Implementation of ICD-10 will accommodate new procedures and diagnoses unaccounted for in the ICD-9 code set and allow for greater specificity of diagnosis-related groups and preventive services.  This transition will lead to improved accuracy in reimbursement for medical services, fraud detection, and historical claims and diagnoses analysis for the health care system.  Many researchers have published articles on the far-reaching positive effects of ICD-10 on quality issues, including use of specific reasons for patient non-compliance and detailed procedure information by degree of difficulty, among other benefits.

Some provider groups have expressed serious concerns about their ability to meet the October 1, 2013 compliance date.   Their concerns about the ICD-10 compliance date are based, in part, on implementation issues they have experienced meeting HHS’ compliance deadline for the Associated Standard Committee’s (ASC) X12 Version 5010 standards (Version 5010) for electronic health care transactions.  Compliance with Version 5010 is necessary prior to implementation of ICD-10.

All covered entities must transition to ICD-10 at the same time to ensure a smooth transition to the updated medical data code sets.   Failure of any one industry segment to achieve compliance with ICD-10 would negatively impact all other industry segments and result in rejected claims and provider payment delays.   HHS believes the change in the compliance date for ICD-10, as proposed in this rule, would give providers and other covered entities more time to prepare and fully test their systems to ensure a smooth and coordinated transition among all industry segments. 

Provisions of the proposed rule announced today

HHS is proposing to change the ICD-10 compliance date to October 1, 2014.

As stated, the ICD-10 compliance date change is part of a proposed rule that would adopt a standard for a unique health plan identifier (HPID), adopt a data element that would serve as an “other entity” identifier (OEID), and add a National Provider Identifier (NPI) requirement.

Standards compliance date

HHS proposes that covered entities must be in compliance with ICD-10 on October 1, 2014.

The proposed rule, CMS-0040-P, may be viewed at www.ofr.gov/inspection.aspx.

A news release on the proposed rule may be viewed at http://www.hhs.gov/news.

View CMS website here.

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CMS News: ICD-10 Implementation date coming in April

From JustCoding.com website, March 20, 2012.

CMS expects to release a new ICD-10-CM/PCS implementation date sometime in April. That date will be the same for payers and providers.

CMS provided the update during a March 7 conference call with payers, according to Renee Washington, director of customer systems integration at MassHealth, who spoke during the March 9 Massachusetts Health Data Consortium ICD-10 Forum conference call.

CMS representatives also stated that it was likely looking at a one-year delay as opposed to a two-year delay, Washington said.

Renee Richard from the CMS Regional Office in Boston confirmed Washington’s information during the call and added that CMS is still considering what process it will use to finalize the new date. “They are really trying to determine the most appropriate, expeditious, and legal vehicle to affect this change. They are trying to work through that process … so they can put a stake in the ground and put out a date for the provider community.”

This article originally appeared on the JustCoding.com website.
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90-day discretionary period of 5010 transactions

CMS has decided to extend the 90-day discretionary period on 5010 transactions.  The original extension was due to expire April 1 but is now extended through June 30, 2012.  CMS is reporting that they are receiving over 90 percent of Part B claims in 5010 format and over 70 percent of Part A claims.  Commercial and State plans are reporting similar numbers.  Providers and other covered entities are being encouraged to use this extra time to work through any final issues that they are having transmitting claims by contacting their vendors and carriers right away.  Further info can be found at http://www.cms.gov/ICD10/.

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ICD-10: It’s been an eventful week

What are your thoughts about the news coming from HHS?  Do you have any predictions of the outcome?

http://www.hhs.gov/news/press/2012pres/02/20120216a.html

Let us know! We want to hear your thoughts!

 

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Article: Medicaid to Stop Reimbursement for Unnecessary ER Visits

Starting on April 1, Medicaid will no longer reimburse for unnecessary emergency room visits in Washington state. 

Read Seattle Times Article:  Here

Carol Ostrom.  “State Medicaid to quit paying for ER visits deemed unnecessary” Seattle Times February 7, 2012.

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CMS Recovery Audit Prepayment Review Demonstration Project

The CMS announced that the Recovery Audit Prepayment Review Demonstration, which was delayed from its initial start date of January 1, 2012, is expected to move forward on or after June 1, 2012.  The Recovery Audit Prepayment Review will allow Recovery Audit Contractors, or 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 have been found to result in high rates of improper payments.  The demonstration project 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) for a total of 11 states. It is expected that the reviews will help lower the error rate by preventing improper payments on the front-end, rather than looking for improper payments after they occur, known as “pay and chase.”  As with the original RAC demonstration projects, if these reviews are successful, and it’s expected that they will be, other states will be included in subsequent roll-outs of the project.

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Modifier 22 – Noridian Administrative Services Processing Change

On January 31, 2012, Noridian Administrative Services (NAS) posted a Medicare Part B News update to Issue 274 dated November 16, 2011.    OF NOTE: NAS no longer requests additional documentation on procedure codes when billed with modifier 22.  Following the initial claim processing and payment, if a provider feels that additional payment is warranted, a Redetermination must be requested.  When submitting the Redetermination request, a separate concise statement explaining the necessity for additional reimbursement must be included.  This separate statement may be in the form of:

•The operative report;

•A separate letter; or

•The “Modifier 22 Explanation Form”

When Modifier 22 is appended to a surgical CPT code, it indicates to the payer that the work required to provide the service was substantially greater than typically required.  Modifier 22 can only be reported with surgical procedure codes that are specified as having a 0, 10 or 90 day global period.  Modifier 22 cannot be submitted with evaluation and management (E/M) procedures.

Documentation must support the substantial additional work and the reason

  • Increased intensity
  • Time (usual time vs. actual time)
  • Technical difficulty of procedure
  • Severity of patient’s condition
  • Physical and/or mental effort required
EXAMPLES:
 
  • Because patient was morbidly obese, cardiac  catheterization required additional 45 minutes beyond typical time required.
  • Patient had extensive and dense adhesions which had to be lysed, increasing the total time of the primary procedure by over an hour. 

Source: Internet Only Manual (IOM) Medicare Claims Processing Manual, Publication 100-04, Chapter 12, Section 40.2 “Unusual Circumstances”

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D-dimer Test Coding Q&A

Question:  “What is the best code for elevated D-dimer test?”

Answer:  Currently there is no official determination as to the best code for this test. 790.6, other abnormal blood chemistry, relates to chemicals/elements in the blood such as cobalt, copper, iron or lead and does not apply. Some coders like 790.92, abnormal coagulation profile. However, the D-dimer test looks for the breakdown of clots, rather than coagulation. Therefore, 790.99, other nonspecific findings on examination of blood, is recommended. The D-dimer test measures the levels of dextro dimer fragments in the blood. This can alert the physician to the presence of venous thromboembolisms. Venous thromboembolisms include both deep venous thromboses and also pulmonary embolisms.

Jane Barta, RHIA, RMC Coding Consultant

Do you have coding questions you would like answered?  Leave us a comment here.

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Coding Question: Modifier 25

Q.1.  I have a question regarding chemo administration and an E&M on the same day.  Due to our remote area, many patients see the physician for their cancer follow up visits on the same day they may be getting chemotherapy.  These visits are distinct E&M visits from the chemo admininstration.  My question is that normally I would append the E&M visit with a  modifier ‘25’,  but the chemo administration is submitted on a UB-04 and then the E&M visit is submitted on a CMS-1500.   Since they are on two different claim forms, would I still need to append the E&M code with a modifier?

A.1.  In this scenario, the chemo administration is being billed by the facility, so it is submitted on the UB-04.  The physician’s portion (the clinic visit) is billed on the CMS-1500 (as long as there is sufficient documentation to support a separate visit).  There is no modifier needed. 

However, if the facility bills an E&M clinic visit plus chemo administration AND there is documentation to support a separate E&M service, modifier 25 would be appropriately appended on the facility E&M visit.

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