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October Medicare Transmittals and Other Updates
Published on 

10/30/2018

20181030

MEDICARE TRANSMITTALS – RECURRING UPDATES

 Changes to the Laboratory National Coverage Determination (NCD) Edit Software for January 2019

The January 2019 quarterly release of the edit module for clinical diagnostic laboratory services.

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/MM10941.pdf

Quarterly Influenza Virus Vaccine Code Update - January 2019

https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2018Downloads/R4141CP.pdf

2019 Annual Update of Healthcare Common Procedure Coding System (HCPCS) Codes for Skilled Nursing Facility (SNF) Consolidated Billing (CB) Update

Updates to edits to allow only those services that are excluded from SNF CB to be paid separately.

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/MM10981.pdf

Notice of New Interest Rate for Medicare Overpayments and Underpayments - 1st Qtr Notification for FY 2019

The Medicare contractors shall implement an interest rate of 10.125 percent effective October 17, 2018 for Medicare overpayments and underpayments.

https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2018Downloads/R307FM.pdf

OTHER MEDICARE TRANSMITTALS

Implementation of the Award for the Jurisdiction F (J-F) Part A and Part B Medicare Administrative Contractor (JF A/B MAC)

The Jurisdiction JF A/B MAC recompetition procurement was recently awarded to Noridian Healthcare Solutions, LLC (Noridian), the incumbent contractor for this workload.

https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2018Downloads/R2143OTN.pdf

Guidance Regarding the Use of Statistical Sampling for Overpayment Estimation

Updates instructions for Unified Program Integrity Contractors (UPICs), Recovery Audit Contractors (RACs), the Supplemental Medical Review Contractor (SMRC), and Medicare Administrative Contractors (MAC) regarding the use of statistical sampling in their reviews and estimation of overpayments.

https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2018Downloads/R828PI.pdf

Local Coverage Determinations (LCDs)

CMS is updating the Medicare Program Integrity Manual with detailed changes to the Local

Coverage Determination (LCD) process.

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/MM10901.pdf

Fiscal Year (FY) 2019 Inpatient Prospective Payment System (IPPS) and Long-Term Care Hospital (LTCH) PPS Changes

Implements Fiscal Year (FY) 2019 policy changes for the Inpatient Prospective Payment System (IPPS) and LTCH PPS.

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/MM10869.pdf

Updating Calendar Year (CY) 2019 Medicare Diabetes Prevention Program (MDPP) Payment Rates

This MLN Matters Article is intended for organizations enrolled as Medicare Diabetes Prevention Program (MDPP) suppliers billing Medicare Administrative Contractors (MACs) for MDPP services provided to Medicare beneficiaries.

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/MM10970.pdf

Medical Review of Diagnostic Laboratory Tests

Clarifies how medical review contractors should review orders for diagnostic laboratory test claims.

https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2018Downloads/R836PI.pdf

MEDICARE SPECIAL EDITION ARTICLES

Activation of Systematic Validation Edits for OPPS Providers with Multiple Service Locations

Medicare systems will validate service facility location to ensure services are being provided in a Medicare enrolled location based on the information submitted on the Form CMS-855A submitted by the provider and entered into the Provider Enrollment, Chain and Ownership System (PECOS).

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/SE18023.pdf

2018-2019 Influenza (Flu) Resources for Health Care Professionals

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/SE18015.pdf

MEDICARE COVERAGE UPDATES

 Magnetic Resonance Imaging (MRI)

Effective for claims with dates of service on and after April 10, 2018, Medicare will allow for MRI coverage for beneficiaries with an Implanted Pacemaker (PM), Implantable Cardioverter Defibrillator (ICD), Cardiac Resynchronization Therapy Pacemaker (CRT-P), or Cardiac Resynchronization Therapy Defibrillator (CRT-D).

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/MM10877.pdf

MEDICARE PRESS RELEASES

 2019 Medicare Parts A & B Premiums and Deductibles

The standard monthly premium for Medicare Part B enrollees will be $135.50 for 2019. The annual deductible for Medicare Part B beneficiaries is $185 in 2019. The Medicare Part A inpatient deductible that beneficiaries will pay when admitted to the hospital is $1,364 in 2019.

https://www.cms.gov/newsroom/fact-sheets/2019-medicare-parts-b-premiums-and-deductibles

MEDICARE EDUCATIONAL RESOURCES

October 2018 Medicare Quarterly Provider Compliance Newsletter

Assists health care professionals to understand the latest findings identified by MACs and other contractors such as Recovery Auditors and the Comprehensive Error Rate Testing (CERT) review contractor, in addition to other governmental organizations such as the Office of the Inspector General (OIG).

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/MedQtrlyComp-Newsletter-MLN8893947.pdf

Medicare Fast Facts

Medicare Fast Facts resources this month include:

  • Proper Use of the KX Modifier for Part B Immunosuppressive Drug Claims

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Fast-Facts.html?DLSort=1&DLEntries=10&DLPage=1&DLSortDir=descending

OTHER MEDICARE UPDATES

September 2018 Patients Over Paperwork Newsletter

An update on CMS’s ongoing work to reduce administrative burden and improve the customer experience while putting patients first.

https://www.cms.gov/Outreach-and-Education/Outreach/Partnerships/POPSeptember2018Newsletter.pdf

ABNs for Dual Eligible Patients
Published on 

10/24/2018

20181024

What’s the difference between nice and kind? Nice is treating others respectfully while kindness involves a deeper caring for others. A recent television commercial presents that it is related to a particular type of snack bar. If you go for the snack bar analogy, what about healthcare coverage? One might say that Medicare coverage for the elderly is a nice program, and that Medicaid for those with limited income and resources is a kind program. I suppose that makes dual eligibility programs both nice and kind.

Some hospital patients will have both Medicare and Medicaid medical coverage. Certain qualified Medicare beneficiaries (known as dual eligible or QMB patients) meet criteria to get help with their Medicare premiums and cost-sharing. According to CMS’s QMB Program webpage, “In 2016, 7.5 million people (more than one out of eight people with Medicare) were in the QMB program.” Because of this program, providers, including hospitals, must bill the state Medicaid program for the patient’s Medicare deductible and co-pays. Patients in the QMB program are not legally obligated to pay providers for any Medicare cost-sharing, even if Medicaid does not pay the entire amount. The webpage noted above also reports that historically there has been confusion and billing errors related to the QMB program. I can certainly understand – dealing with Medicare rules by themselves is challenging enough – the challenge doubles when there are two government payers. I recommend billers mark the QMB webpage for future reference. It offers numerous resources and information about the QMB program, such as a list of QMB Frequently Asked Questions.

One new question and answer in the QMB FAQs deals with billing limitations and special instructions when an Advance Beneficiary Notice (ABN) is given to a dual eligible patient. An ABN is given to a Medicare patient when the item or service being provided is expected to be denied by Medicare as not reasonable and necessary (medical necessity denial). The ABN notifies patients they will be financially liable for the service and allows them the option to elect to have the service or not. When presenting an ABN to a dually eligible Medicare/Medicaid patient, the provider:

  • Directs the patient to select Option 1, which requires a claim be submitted to Medicare for an official decision on payment. (Note: This is the only time a provider may direct a patient as to which option to select.)
  • CANNOT require payment from the patient at the time of the service. In fact, the provider cannot bill the patient until the claim is adjudicated by both Medicare and Medicaid.
  • Submits a cross-over claim to Medicaid if Medicare denies payment.
  • Can shift liability to the patient based on Medicare policy and state laws if the claim is denied by Medicare as not medically necessary and if coverage is denied by Medicaid (or not paid for other reasons).

Dual eligible patients are also liable for Medicare statutorily excluded services if the patient or the services are not covered by Medicaid. Although an ABN is not required to be given for statutorily excluded services, it is a nice courtesy to ensure patients are aware of their potential financial liability. Or maybe even kind. The world certainly needs more niceness and kindness.

Debbie Rubio

ICD-10-PCS Codes Re-Designated as O.R. or Non-O.R. 2019 IPPS Final Rule
Published on 

10/16/2018

20181016
 | Coding 

The designation of an ICD-10-PCS code designated as an O.R. or Non-O.R. procedure affects the MS-DRG assignment. Codes designated as an O.R. procedure will group the inpatient stay to a surgical MS-DRG. Codes designated as Non-O.R. procedures would not impact the MS-DRG assignment so the inpatient stay would be grouped to a Medical MS-DRG. In general, surgical MS-DRGs are a higher relative weight meaning higher payment for the inpatient stay.

The transition of procedure code re-designation began with CMS including proposals in the FY 2017 IPPS Proposed Rule.  In the FY 2017 IPPS Final Rule, CMS indicated they had received requests and recommendations for over 800 procedure codes and were unable to fully evaluate and finalize comments received for FY 2017. A year later, allowing for time to evaluate requests and recommendations, CMS did in fact propose to re-designate over 800 current ICD-10-PCS codes as Non-O.R. Procedures in the Proposed Rule and finalized 770+ code re-designations.

CMS noted “the proposed changes for FY 2018 go beyond the FY 2017 proposed (and finalized) MS-DRG updates to change the designation of procedure codes from O.R. to non-O.R. that were done for purposes of replicating the logic of the ICD-9 MS-DRGs….for FY 2018 and future fiscal years, we are no longer replicating the ICD-9 MS-DRGs…we are using ICD-10 coded claims data for the first time to propose changes to the ICD-10 MS-DRG classifications and to compute the relative weights. Therefore, our proposals and final policies for FY 2018 are based solely on the ICD-10 claims data from the FY 2016 MedPAR file.”

FY 2019 IPPS Final Rule

CMS continued reviewing ICD-10 claims data for FY 2019 and finalized the re-designation of nine (9) ICD-10-PCS codes from O.R. Procedures to Non-O.R. Procedures and seventy (70) ICD-10-PCS codes from Non-O.R. to O.R. The following two tables detail the volume of codes changed by Code Group. 

Code Groups Finalized for Re-Designation to Non-O.R. Procedures
Finalized Number of Codes Code Group
5 Drainage of Lower Lung Via Natural or Artificial Opening Endoscopic, Diagnostic
4 Endoscopic Destruction of Intestine
Source: 2019 IPPS Final Rule (CMS-1694-F). Link to 2019 Final Rule webpage: https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/AcuteInpatientPPS/FY2019-IPPS-Final-Rule-Home-Page.html
Code Groups Finalized for Re-Designation to O.R. Procedures
Finalized Number of Codes Code Group
22 Percutaneous & Percutaneous Endoscopic Excision of Brain and Cerebral Ventricle
13 Open Scrotum and Breast Procedures
8 Open Parotid Gland and Submaxillary Gland Procedures
8 Removal and Reinsertion of Spacer; Knee Joint and Hip Joint
3 Endoscopic Dilation of Ureter(s) with Intraluminal Device
9 Thoracoscopic Procedures of Pericardium and Pleura
10 Totally Implantable Vascular Access Device
Source: 2019 IPPS Final Rule (CMS-1694-F). Link to 2019 Final Rule webpage: https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/AcuteInpatientPPS/FY2019-IPPS-Final-Rule-Home-Page.html

 Potential Financial Impact of Changes

In the absence of a valid O.R. Procedure code, hospitals will still receive reimbursement for the Medical Principal Diagnosis. The challenge is to identify the potential financial impact of the MS-DRG shift from a Surgical MS-DRG to a Medical MS-DRG. To do this I turned to our sister company, RealTime Medicare Data (RTMD) to provide the CY 2017 paid claims data for Alabama for all ICD-10-PCS codes with an O.R. Procedure re-designation where it was the Principal Procedure on the paid claim. This following table highlight the O.R. to Non-O.R. Re-designation findings.

 

CY 2017 Alabama Claims Analysis Procedure Codes Re-Designated as Non-O.R. Procedures
Section Title Volume Total Charges Actual Amount Paid
Drainage of Lower Lung Via Natural or Artificial Opening Endoscopic, Diagnostic 206 $27,199,796.61 $4,608,610.81
Endoscopic Destruction of Intestine 12 $762,537.80 $186,312.55
Overall 218 $27,962,334.41 $4,794,923.36
Source: RTMD Paid Claims Data for the state of Alabama in CY 2017

MMP conducted a similar review of the changes made in FY 2018. Through claims analysis we were able to identify the Medical MS-DRG that would have been billed in the absence of the O.R. procedure. In general, we found that hospitals could expect anywhere from a 35% to 45% decrease in payment. Applying the same findings to FY 2019, that would equate to the state of Alabama realizing a potential $1.6 million to $2.1 million decrease in paid claims revenue.

This last table highlights the Non-O.R. to O.R. re-designation findings.

CY 2017 Alabama Claims Analysis Procedure Codes Re-Designated as O.R. Procedure Codes
Section Title Volume Total Charges Actual Amount Paid
Percutaneous and Percutaneous Endoscopic Excision of Brain and Cerebral Ventricle 7 $3,111,250.28 $309,779.31
Open Scrotum and Breast Procedures 29 $1,082,778.38 $147,911.17
Open Parotid Gland and Submaxillary Gland Procedures 1 $35,232.74 $4,022.95
Removal and Reinsertion of Spacer, Knee and Hip Joint 8 $715,415.22 $45,413.23
Endoscopic Dilation of Ureter(s) with Intraluminal Device 0 0 0
Thoracoscopic Procedures of Pericardium and Pleura 24 $933,235.26 $105,235.83
Totally Implantable Vascular Access Device 21 $1,743,481.79 $162,275.02
Overall 90 $7,621,393.67 $774,637.51
Source: RTMD Paid Claims Data for the state of Alabama in CY 2017

 If you reverse the expected decrease in payment to an expected increase of 35% to 45%, this would equate to the state of Alabama realizing a potential $271,000 to $348,000 increase in paid claims revenue.

For those interested, detailed discussion about the ICD-10-PCS code re-designations can be found on pages 41249 through 41257 of the Final Rule.  

Beth Cobb

FAQ - HCPCS code for injectable isoproterenol
Published on 

10/16/2018

20181016
 | FAQ 

Q:

We have a new physician that wants to use isoproterenol injections for ablation procedures.  Is there a HCPCS code for this drug as an injectable?  If there is not a specific code for it, would this drug qualify for the C9399 code? Is there any reimbursement for this drug? It is high cost and we want to evaluate the financial impact of using it.


A:

Isoproterenol has been around for years, so C9399 would not be applicable unless there is a formulation one of the drug newly released from the FDA.

There are HCPCS codes available for the inhalation form of isoproterenol, but I am not aware of a HCPCS code for the injectable form.  Without a HCPCS code, you will have to report the drug without a HCPCS code and revenue code 250, thus, no separate reimbursement for that line item drug.

Jeffery Gordon

Newest Issues for Medicare Reviewers
Published on 

10/16/2018

20181016
No items found.

This week, during a school fall break, I went to the zoo with my grandchildren. This presented the perfect opportunity to teach my young granddaughter the famous phrase from the movie The Wizard of Oz, “Lions, and tigers, and bears. Oh my!” For those of us that deal with Medicare reviews, there are no literal lions, and tigers and bears, but we do sometimes have a reason to fear. Our refrain could be “MACs, and RACs, and CERT. Oh my!” Below is a discussion of the latest review issues and concerns from some of these types of reviewers.

There was not a lot of new medical review activity by Medicare Administrative Contractors (MACs) this month in the Targeted Probe and Educate (TPE) program. Some MACs remain silent on their review topics. Whether this means they are not conducting any reviews or are not sharing that information on their websites is unknown. Novitas, the MAC for Jurisdictions H and L, added new topics for reviews focused on DRG validation and partial hospitalization programs (PHP) for outpatient psychiatric services. DRG validation reviews generally focus on coding accuracy and the codes being supported by documentation in the medical record. WPS J5 reported on their TPE review of DRG validation with excellent results – no providers moved on to Round 2 so this review appears to be concluded for J5.

For the partial hospitalization program review, the PHP Checklist on the Novitas website indicates they expect to see:

  • An initial psychiatric evaluation, including history and mental status examination,
  • Physician certification/recertification and documentation of physician supervision,
  • Description of illness requiring services, and psychiatric diagnosis to support medical necessity,
  • Documentation that the services are designed to reduce or control psychiatric symptoms so as to prevent inpatient hospitalization and to improve or maintain the patient’s level of functioning,
  • Progress notes for each service rendered, and
  • Documentation to support a minimum of 20 hours per week of therapeutic services.

Novitas also released results of their Round 1 review of Hyperbaric Oxygen Therapy (HBO). Denials rate for HBO ranged from approximately 2% to 35% in JH and from approximately 20% to 56% in JL. Insufficient documentation is the reason for all denials. Records lacked documentation of medical necessity, treatments, physicians’ orders, tests/notes to support the diagnosis being treated, response to treatment or measurable signs of healing, and failed standard treatment of diabetic wounds.

Over the past few months, Recovery Auditors, still commonly referred to as RACs, have added new issues.

  • In July, APC Validation was added to all RAC regions. This is a coding review to verify procedures are assigned CPT/HCPCS codes accurately and that “match both the attending physician description and the information contained in the beneficiary's medical record. Reviewers will validate the APC by reviewing the procedures affecting or potentially affecting the APC assignment.”
  • HMS, the RAC for Region 4, posted a review of facet injections at the end of August. HMS quotes information from several Local Coverage Determinations (LCDs) – L34993, L34974, and L34892 – that describe the requirements for injections and blocks. For example, pain must have been present for 3 months or greater and a detailed pain history is essential and must provide information about prior treatment and responses, such as analgesics and physical therapy, for paravertebral facet joint injections.
  • A new issue for Cotiviti RAC Regions 2 and 3 from September is the review of the medical necessity of transthoracic echocardiography (TTE) for hospital inpatients and outpatients, and patients in a skilled nursing facility (SNF). The medical necessity of this procedure will be based in large part on the requirements as described in several LCDs. Please refer to the LCD for your MAC region to determine the specific indications and requirement for TTE. For example, the Palmetto LCD includes such statements as:
  • When there are no signs or symptoms of heart disease, the use of TTE is not covered for hypertension.
  • The role of TTE in the emergency room assessment of individuals presenting with chest pain is not defined at this time. This use is not accepted as a standard-of-care. For TTE to be allowed, clinical findings supporting myocardial dysfunction must be present. When these findings are not present, this use is not covered.
  • TTE is used annually in follow-up of chronic valvular disease to document the course over time. Generally, it is not medically necessary to repeat these examinations more frequently than annually. When the patient’s plan of care includes imminent valvular surgery, more frequent exams may be necessary.

Other RAC issues affecting outpatient hospitals are discussed in the Medicare Quarterly Provider Compliance Newsletters. The July newsletter explains that Vagus Nerve Stimulation is only considered reasonable and necessary for patients with medically refractory partial onset seizures for whom surgery is not recommended or for whom surgery has failed. It is not covered for other types of seizure disorders or for resistant depression. The article goes on to list the specific ICD-10-CM diagnosis codes that are covered for vagus nerve stimulation. The October newsletter has an article on outpatient services overlapping or during an inpatient stay. Please refer to a June Wednesday@One article for information on how to avoid overlapping claims.

As you can see, there is a smorgasbord of issues for review as usual. Hospital providers have to constantly be on the lookout for lions, and tigers, and bears. Oh my!!

Debbie Rubio

Alert: October 3, 2018 CMS Publishes Correction to Codes to Identify New Technology approved for Add-On Payment
Published on 

10/9/2018

20181009
 | Billing 

MMP initially ran this article September 12, 2018, click here to read the original article. Since then CMS posted a correction to the 2019 IPPS Final Rule on October 3rd. This correction included the following important update to inpatient cases involving the drug VABOMERE™ which is available for a new technology add-on payment.

Notice in 2019 IPPS Final Rule Correction published in the Federal Register October 3, 2018:

“On page 41311, we made a typographical error in describing which National Drug Code (NDC) will be used to identify cases involving VABOMERE™ that are eligible for new technology add-on payments in FY 2019. Specifically, we are correcting the NDC code of 65293–0009–01, which erroneously was missing an extra digit. In addition, we were made aware after the final rule that NDC 70842–0120–01 can also be used to identify cases of VABOMERETM. Therefore, cases involving the use of VABOMERE™ that are eligible for new technology add-on payments in FY 2019 will be identified with either of the following NDCs: 65293–0009–01 and 70842–0120–01.”

New Technology

Melinta Therapeutics, Inc.’s application for new technology add-on payments for VABOMERE™ for FY 2019 was approved by CMS. The maximum new technology add-on payment for cases involving the use of VABOMERE™ for FY 2019 is $5,544.

What is VABOMERE™ (Meropenem-vaborbactam)?

VABOMERE™ is a combination product containing meropenem and vaborbactam. This drug is indicated for treating adult patients diagnosed with complicated urinary tract infections (cUTIs), including pyelonephritis caused by the following susceptible microorganisms: Escherichia coli, Klebsiella pneumoniae, and Enterobacter cloacae species complex.

Issue

There is no unique ICD-10-PCS procedure code for VABOMERE™ for FY 2019 leaving hospitals with no way to uniquely identify the use of VABOMERE™ on an inpatient claim.

How to identify the use of VABOMERE™ on an Inpatient Claim

CMS revised their policy to allow the use of an alternative code set to identify an oral medication when there is no inpatient procedure code for purposes of new technology add-on payments in the FY 2013 IPPS Final Rule. Specifically, they adopted the National Drug Code (NDC) as an alternative code set to identify the use of DIFICID™ effective for discharges on or after October 1, 2012.

While VABOMERE™ is administered by IV infusion and not orally, CMS acknowledges that “it is the first approved new technology aside from an oral drug with no uniquely assigned inpatient procedure code” and believes for purposes of identifying the use of VABOMERE™ this is a similar circumstance to the use of DIFICID™.

For FY 2019, cases eligible for the FY 2019 new technology add-on payments will be identified by the NDC code 65293-0009-01 (VABOMERE™ Meropenem-Vaborbactam Vial) or NDC code 70842-0120-01. Providers must code the NDC in data element LIN03 of the 837i Health Care Claim Institutional form in order to receive the new technology add-on payment for procedures involving the use of VABOMERE™.”

Who Needs to Know this Information?

Your hospital Pharmacy should be made aware of this information so they can collaborate with your Billing Office to ensure you receive the add-on payment for eligible claims.

Resources

Billing guidance can be found on page 49837 of the October 3, 2018 Final Rule Correction Notice published in the Federal Register which can be accessed from the CMS FY 2019 IPPS Final Rule Homepage at https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/AcuteInpatientPPS/FY2019-IPPS-Final-Rule-Home-Page.html.

Additional information about VABOMERE™ can be found on the Melinta Therapeutics, Inc. website at http://www.vabomere.com/.

Beth Cobb

FAQ - Hydration and radiological studies with IV contrast
Published on 

10/9/2018

20181009
 | FAQ 

Q:

We are doing hydration infusions pre- and post-IV contrast studies (e.g., CT, IVP, etc.) for patients with elevated creatinine levels.  The question was asked whether we should be charging for it.  Can we report hydration infusions in this scenario (CPT codes 96360, 96361)?


A:

The definitive documentation you need is in Coding Clinic for HCPCS, 3Q 2007, pages 6-9.

In that discussion, they say hydration ‘cannot’ be reported in that scenario, with the specific example of a patient with an elevated creatinine receiving IV hydration to prevent damage to the kidneys.

Hydration is incidental to the CT scan, and not separately reportable.

There is a similar Coding Clinic article (4Q 2007, page 6) asking about patients with mitral valve prolapse coming in for an endoscopy, who are given a prophylactic antibiotic. Again, administration of the antibiotic is part of the pre-procedure preparation and should not be reported separately.

Jeffery Gordon

CMS Proposes Reforming Burdensome Regulations
Published on 

10/2/2018

20181002

One frustration of healthcare workers is that they spend almost as much time on documentation and complying with burdensome regulations as they do taking care of patients. The current government Administration has promised to provide some relief by removing unnecessary, obsolete or excessively burdensome Medicare compliance requirements for healthcare facilities. To this end, the Centers for Medicare and Medicaid Services (CMS) released a proposed rule on September 17, 2018 reforming some Medicare regulations to reduce the amount of time and resources that healthcare facilities have to spend on CMS-mandated compliance activities that do not improve the quality of care. According to the CMS Administrator, this will allow hospitals and healthcare professionals to focus on their primary mission of treating patients.

Here are some of the proposals to change the Medicare Conditions of Participation (CoP) that affect hospitals either directly or indirectly:

  • Hospital systems could elect to have one unified and integrated Quality Assessment and Performance Improvement (QAPI) program for all of its member hospitals instead of individual programs for each hospital. Such a program must be in compliance with State and local laws, consider the unique circumstances and differences of the member hospitals, and be able to address needs and issues specific to each hospital.
  • Hospitals could establish a medical staff policy that would allow a pre-surgery/pre-procedure assessment for an outpatient in certain circumstances, instead of a comprehensive medical history and physical examination (H&P). The assessment would have to be documented in the patient’s medical record. The hospital’s policy would have to consider medical factors (such as the patient’s diagnosis and other conditions, type of surgery, etc.), nationally recognized guidelines and standards of practice, and applicable state and local health and safety laws.
  • Like the above described unified quality program, the rule also proposes allowing a unified and integrated infection control program for multi-hospital systems. The same considerations of the differences and unique needs of each hospital apply for a unified infection control program as they do for the unified quality program.
  • Hospitals and other facilities are required by law to have processes for cooperation and collaboration with local, tribal, regional, State and Federal emergency preparedness officials’ efforts to maintain an integrated response during a disaster or emergency situation. This requirement is not changed but the requirement to document participation in collaborative and cooperative planning efforts, including documentation of contact efforts, is proposed to be eliminated. There are also proposals to provide flexibility in the time frame of review of Emergency Preparedness plans, decrease the required frequency of training to every two years instead of annually, and allow flexibility in the types of testing exercises for both inpatient and outpatient exercises.
  • Remove the requirement for hospitals to perform autopsies in all cases of unusual deaths and of medical-legal and educational interest. Hospitals would follow State laws regarding such medical-legal requirements.

There are also proposals that address changes to critical access hospitals (CAHs) annual review of policies and procedures, hospital and CAH swing-bed requirements, requirements for transplant centers, and clarification of who is allowed to document progress notes in a psychiatric hospital. Other proposals address different types of providers.

One proposal for ambulatory surgery centers (ASCs) may be of interest to hospitals. CMS is proposing to remove the requirement that ASCs have a transfer agreement with a hospital and that the ASC surgeons have admitting privileges at a hospital. CMS sites hospitals’ refusals to sign such agreements and the EMTALA requirements that hospitals must treat emergencies as reasons why the current requirements do not affect patient safety and therefore are no longer needed.

If you would like more information, please refer to the proposed rule, the press release, and/or the CMS Fact Sheet.  

Debbie Rubio

Outpatient FAQ October 2018
Published on 

10/2/2018

20181002
 | FAQ 

Q:

We have documentation that a PICC line nurse inserted a “PIV” in the patient’s right lower arm with a 20-gauge needle / angiocath. If the nurse had also documented the vein as the cephalic, basilic, or dorsalic, could we report this as a PICC line insertion, CPT code 36569?

A:

This sounds like a regular IV start that happened to be done by the PICC nurse.

Usually, if the PICC nurse puts in a true PICC line, they will specifically call it a PICC line. In your question, the PICC nurse calls it a PIV = peripheral IV, and they used a 20-gauge needle.

In order to report a PICC line, you would also need documentation of the final position of the catheter tip in a central vessel or right atrium – per CPT guidelines.

We usually see this documented by a chest x-ray or with a tip confirmation system like Sherlock.

Based on the details stated in the question, and assuming the PIV will be used for medications and/or IV fluids, there is not a CPT code to report.

It’s just an IV start - - even if it was difficult and required the skills of a PICC nurse.

Jeffery Gordon

Inpatient FAQ October 2018
Published on 

10/2/2018

20181002
 | FAQ 

Q:

Should decompression/release of a spinal nerve root be assigned along with the spinal fusion code(s) if the decompression is performed at the site of the fusion?


A:

Yes, if there is a distinct intent, then both release and the fusion can be coded at the same level.  This issue will be addressed in an upcoming Coding Clinic.

Resource: Maria Ward, MEd, RHIT, CCS, CCS-P, Director, HIM Practice Excellence, Coding Services at AHIMA

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