Knowledge Base Category -

Question

A patient was transferred from a nursing home with a Foley and was found to have a UTI upon admission.  Should we always query to see if the UTI was caused by the Foley catheter?

Answer

Yes.  Patients that have an indwelling catheter are susceptible to bacteria in the urine and UTIs.  If the UTI was caused by the Foley, code T83.511A (Infection and inflammatory reaction due to indwelling urethral catheter, initial encounter) should be assigned as the principal diagnosis.  A code for the UTI should also be assigned as a secondary diagnosis.  A catheter-associated urinary tract infection is also called a (CAUTI).  Coding the CAUTI as the principal diagnosis may also affect the DRG assignment.

It’s good practice to review the chart for supporting evidence of the presence of a Foley catheter or another kind of urinary catheter/device, when a UTI is diagnosed. 

References:

Merck Manual

AHA Coding Handbook

The Program for Evaluating Payment Patterns Electronic Report or PEPPER is one resource available to providers to help guide your selection of meaningful review targets for audits. According to the PEPPER User’s Guide for Short-Term Acute Care, this report “contains a single hospital’s claims data statistics for Medicare-Severity Diagnosis-Related Groups (MS-DRGs) and discharges at risk for improper payment due to billing, coding, and/or admission necessity issues…All of the data tables, graphs, and reports in PEPPER were designed to assist the hospital in identifying potential overpayments as well as potential underpayments.”

If you attempted to access the PEPPER Resources website in December 2023, you were directed to a blank page. This week I once again checked this website and the following notice has been posted:

“Updates to the Program for Comparative Billing Reports (CBRs) and Evaluating Payment Patterns Electronic Report (PEPPERs) Coming Soon

There will be a temporary pause in distributing CBRs and PEPPERs as CMS works to improve and update the program and reporting system. This pause will remain in effect through the fall of 2024. We recognized the importance of these reports to your practice. Therefore, during this time, CMS will be working diligently to enhance the quality and accessibility of the reports. In fulfilling this commitment, your feedback is requested. In the near future, CMS will release a Request for Information (RFI) to obtain information from you, the provider community, about how the program can better serve you.

Please visit CBR and PEPPER website for periodic updates. If you have further questions please send them to Medicaremedicalreview@cms.hhs.gov.”

About CBRs

Question

We have outpatient lab orders on patients that frequently have a host of lab tests performed including Microalbumin/Creatinine Ratio and Urine Drug Screen, CPT® codes 82570, 82043, 80307. There are separate orders & results for all 3 tests.  All may have the same diagnoses or different diagnoses.

I have read the NCCI edit about specimen validity, but in this case, these tests appear to be ordered for specific diagnoses, they have separate orders and results. Would 59 be appropriate on 82570?

Answer

Yes, modifier 59 can be used when CPT® code 82570 (urine creatinine) is ordered and resulted separately, and when the urine creatinine is “not” performed for specimen validity testing.

To support this opinion, we used the NCCI policy statement you referenced above (NCCI Policy Manual, chapter X, section E.2, page X-7) Link

Current Procedural Terminology (CPT) codes, descriptions and other data only are copyright 2023 American Medical Association. All rights reserved.  CPT® is a registered trademark of the American Medical Association.

In a November 16^th Press Release HHS announced three new key resources to “build on the Administration’s work to advance health equity by acknowledging that peoples’ social and economic conditions play an important role in their health and wellbeing.”

White House Resource: U.S. Playbook to Address Social Determinants of Health (SDOH)

HHS defines SDOH as “the conditions in the environment where people are born, live, learn, work, play, worship, and age that affect a wide range of health, functioning, and quality-of-life outcomes and risks.”

The White House’s vision is for every American to lead full and healthy lives within their community. “This Playbook lays out an initial set of structural actions federal agencies are undertaking to break down these silos and to support equitable health outcomes by improving the social circumstances of individuals and communities.” The playbook groups actions into the following three pillars:

• Pillar 1: Expanding Data Gathering and Sharing,
• Pillar 2: Support Flexible Funding to Address Social Needs,
• Pillar 3: Support Backbone Organization.

   

  HHS Resource: Medicaid and Children’s Health Insurance Program (CHIP) Health-Related Social Needs (HRSN) Framework

  In a related Press Release HHS notes “the Playbook highlights ongoing and new actions that federal agencies are taking to support health by improving the social circumstances of individuals…The second resource provides guidance “to structure programs that address housing and nutritional insecurity for enrollees in high need populations.”

   

  HHS Resource: HHS’s Call to Action to Address Health Related Social Needs

  The third document is meant to “encourage cross-sector partnerships among those working in health care, social services, public and environmental health, government, and health information technology to create a stronger, more integrated health and social care system through shared decision making and by leveraging community resources, to address unmet health related social needs.”

   

  Z-Codes: Identifying and Coding Social Determinates of Health

  Identifying and coding SDOH supports quality measurement, planning, and implementation of social needs, and identifying community population needs. This data can be used to advocate for updating and creating new policies. For example, effective October 1, 2023, the severity designation for three Z codes was changed to a CC (comorbidity or complication) for purposes of MS-DRG assignment:

• Z59.00: Homelessness, unspecified,
• Z59.01: Sheltered homelessness (due to economic difficulties, currently living in a shelter, motel, temporary or transitional living situation, scattered site housing, or not having a consistent place to sleep at night), and
• Z59.02: Unsheltered homelessness (residing in a place not meant for human habitation, such as cars, parks, sidewalks, or abandoned buildings (on the street)).

CMS noted in a FY 2024 IPPS Final Rule Fact Sheet that as SDOH codes are increasingly added to billed claims, they plan “to continue to analyze the effects of SDOH on severity of illness, complexity of services, and consumption of resources.” 

To help with understanding and coding Z Codes, CMS has published an infographic titled Improving the Collection of Social Determinants of Health (SDOH) Data with ICD-10-CM Z Codes. This document defines Z codes, explains the importance of collecting them and includes recent SDOH Z Code Categories and new codes effective October 1, 2023.

A related Journey Map walks you through five steps to using Z codes and how using these codes can enhance your quality improvement initiatives.

Question

A patient was admitted to the hospital with acute renal failure and has a history of a kidney transplant.  Is acute renal failure a complication of the kidney transplant?

Answer

Acute renal failure is affecting the function of the transplanted kidney, but it doesn’t mean that the transplant itself has failed.  Assign T86.19 (Other complication of kidney transplant) along with N17.9 (Acute renal failure) to correctly code this case.

• Pre-existing conditions or conditions that develop after an organ transplant are not coded as complications unless it affects the function of the transplanted organ.

References:

Coding Clinic for ICD-10-CM/PCS, Second Quarter 2019:  Page 7

AHA Coding Handbook

Coverage Updates

October 30, 2023: MLN MM13017: Removal of a National Coverage Determination & Expansion of Coverage of Colorectal Cancer Screening – Revised

The initial release of this MLN article was February 2, 2023. Now in it’s third iteration, CMS has added clarifying information about the -KX modifier for screening colonoscopy claims in the context of a complete colorectal cancer screening. https://www.cms.gov/files/document/mm13017-removal-national-coverage-determination-expansion-coverage-colorectal-cancer-screening.pdf

November 20, 2023: MLN MM13429: Beta Amyloid Positron Emission Tomography in Dementia and Neurodegenerative Disease

On October 13, 2023 CMS published a Final Decision Memo announcing a final decision to remove this NCD and now permitting Medicare coverage determinations to be made by the MACs. Removing the NCD also removes the current limitation of one PET beta-amyloid scan per lifetime from the coverage requirements.

CMS notes in MLN article MM13429 that “your MAC will adjust any PET beta amyloid claims processed incorrectly that you bring to their attention, effective for claims with DOS on or after October 13, 2023. https://www.cms.gov/files/document/mm13429-beta-amyloid-positron-emission-tomography-dementia-and-neurodegenerative-disease.pdf

Compliance Education Updates

MLN Educational Tool: Medicare Payment Systems

CMS has updated this tool to include FY 2024 updates to the:

• Acute Care Hospital Inpatient Prospective Payment System,
• Hospice Payment System & Coverage,
• Inpatient Psychiatric Facility Prospective Payment System,
• Inpatient Rehabilitation Facility Prospective Payment System,
• Long-Term Care Hospital Prospective Payment System, and
• Skilled Nursing Facility Prospective Payment System.

Substantive changes to this tool are in dark red. https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/html/medicare-payment-systems.html

October 2023: MLN Booklet: Independent Diagnostic Testing Facility

CMS has updated this booklet to include more information on several topics, including supervising physicians, interpreting physicians, and technicians. https://www.cms.gov/files/document/mln909060-independent-diagnostic-testing-facility.pdf

New and Updated CMS National Training Program (NTP) Products

• Medicare & the Health Insurance Marketplace^®
• Medicare: Getting Started
• Medicare & Home Health Care

You can order CMS products in bulk by visiting our product ordering website.

October 30, 2023: MLN MM13390: ICD-10 & Other Coding Revisions to National Coverage Determinations: April 2024 Update (CR 1 of 2)

CMS advises providers to make sure your billing staff knows about newly available codes, recent coding changes, and NCD coding information.  https://www.cms.gov/files/document/mm13390-icd-10-other-coding-revisions-national-coverage-determinations-april-2024-update-cr-1-2.pdf

October 30, 2023: MLN MM13391: ICD-10 & Other Coding Revisions to National Coverage Determinations: April 2024 Update (CR 2 of 2)

CMS advises providers to make sure your billing staff knows about newly available codes, recent coding changes, and NCD coding information. https://www.cms.gov/files/document/mm13391-icd-10-other-coding-revisions-national-coverage-determinations-april-2024-update-cr-2-2.pdf

November 3, 2023: MLN MM13244: Separate Payment for Disposable Negative Pressure Wound Therapy Devices on Home Health Claims

Effective January 1, 2024, Medicare will make separate payment for HCPCS code A9272 on type of bill (TOB) 032x, instead of 034x. Also, Medicare Administrative Contractors (MACs) will apply deductible and coinsurance.

https://www.cms.gov/files/document/mm13244-separate-payment-disposable-negative-pressure-wound-therapy-devices-home-health-claims.pdf

November 6, 2023: MLN MM13055: Allowing Audiologists to Provide Certain Diagnostic Tests Without a Physician Order – Revised

Initially published June 1, 2023, this article was revised on November 6, 2023 to add two new CPT codes effective January 1, 2024, based on Change Request (CR) 13279.

Did You Know?

Effective October 1, 2023, the Alphabetic Index to the code book changed how we are to code elevated Troponin level again.

Why It Matters?

Prior to October 1, 2023, the Alphabetic Index led coders to assign R77.8, Other Specified Abnormalities of Plasma Protein, for an elevated Troponin level, while the advice from Coding Clinic, 2Q 2019, page 6 instructed coders to use R79.89, Other Specified Abnormal Lab Findings of Blood Chemistry. Even though the code book instructions take precedence over Coding Clinic advice, this confused many coders and caused coding errors when coding this condition.

What Can I Do?

Inform coders that the Alphabetic Index has now changed and that R79.89, Other Specified Abnormal Lab Findings of Blood Chemistry is the correct code for an elevated Troponin level.

Resources:

Coding Clinic, 2Q 2019, page 6

Alphabetic Index from the code book, 10/01/2023

CMS issued the CY 2024 OPPS/ASC Final Rule on November 2, 2023. This article highlights changes to the Medicare Inpatient Only (IPO) Procedure list and the ASC Covered Procedure List (CPL)

Medicare IPO Procedure List

Although CMS received several requests recommending services for removal from the IPO list, CMS did not find sufficient evidence that met the criteria, and no services were removed from the IPO list for CY 2024. CMS finalized their proposals to add nine services with newly created codes by the AMA CPT Editorial Panel which will be in effect January 1, 2024 to the list and to reassign CPT code 0646T (Transcatheter tricuspid valve implantation (ttvi)/replacement with prosthetic valve, percutaneous approach, including right heart catheterization, temporary pacemaker insertion, and selective right ventricular or right atrial angiography, when performed) from status indicator “E1” (not payable by Medicare) to status indicator “C.” Changes to the IPO list are in table 103 of the final rule.

ASC Covered Procedures List (CPL)

In regard to expanding the ASC CPL, CMS notes in the final rule that “while expanding the ASC CPL offers benefits, such as preserving the capacity of hospitals to treat more acute patients and promoting site neutrality, we also believe that any additions to the CPL should be added in a carefully calibrated fashion to ensure that the procedure is safe to be performed in the ASC setting for a typical Medicare beneficiary. We expect to continue to gradually expand the ASC CPL, as medical practice and technology continue to evolve and advance in future years.” 

In the CY 2024 proposed rule, CMS proposed to update the ASC CPL by adding 26 dental surgical procedures.

Before we find out what was finalized. It is relevant to share information from the CY 2023 and CY 2024 Physician Fee Schedule (PFS) final rules where CMS provides greater clarity to current policies related to dental services. Specifically, in the CY 2023 final rule CMS provided:

1. A clarification of our interpretation of section 1862(a)(12) of the Act to permit payment for dental services that are inextricably linked to other covered services.
2. clarification and codification of certain longstanding Medicare FFS payment policies for dental services that are inextricably linked to other covered services.
3. that, beginning for CY 2023, Medicare Parts A and B payment can be made for certain dental services inextricably linked to Medicare-covered organ transplant, cardiac valve replacement, or valvuloplasty procedures; and,
4. beginning for CY 2024, that Medicare Parts A and B payment can be made for certain dental services inextricably linked to Medicare-covered services for treatment of head and neck cancers (87 FR 69670 and 69671).

CMS also clarified that adding dental procedures to the ASC CPL does not serve as a coverage determination for dental services under anesthesia.

The CY 2024 Physician Fee Schedule Final Rule was also issued on November 2, 2023. In a related Fact Sheet CMS notes for CY 2024 they are building up on their efforts and for CY 2024 are finalizing the following:

1. A codification of the previously finalized payment policy for dental services for head and neck cancer treatments, whether primary or metastatic.
2. The codification to per Medicare Part A and Part B payment for dental or oral examination performed as part of a comprehensive workup prior to medically necessary diagnostic and treatment services, to eliminate an oral or dental infection prior to, or contemporaneously with, those treatment services, and to address dental or oral complications after radiation, chemotherapy, and/or surgery when used in the treatment of head and neck cancer; and
3. The proposal to permit payment for certain dental services inextricably linked to other covered services used to treat cancer prior to, or during chemotherapy services, Chimeric Antigen Receptor (T (CAR-T) Cell therapy, and the use of high-dose bone modifying agents (antiresorptive therapy).

CMS has finalized the addition of 37 procedures to the ASC CPL. In addition to the proposed 26 dental surgical procedures, CMS finalized adding 11 of 235 procedure recommendations received during the public comment period. They note that “these 11 codes correspond to procedures that are frequently performed in outpatient settings and increasingly show lower risks of serious complications and inpatient admissions.” The procedures are listed in Table 123 of the CY 2024 OPPS/ASC final rule.

Resources

CY 2024 OPPS/ASC Final Rule: https://www.cms.gov/medicare/payment/prospective-payment-systems/hospital-outpatient/regulations-notices/cms-1786-fc

CY 2024 OPPS/ASC Final Rule Fact Sheet: https://www.cms.gov/newsroom/fact-sheets/cy-2024-medicare-hospital-outpatient-prospective-payment-system-and-ambulatory-surgical-center-0

CY 2024 Medicare Physician Fee Schedule Final Rule Fact Sheet: https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2024-medicare-physician-fee-schedule-final-rule

CMS issued the CY 2024 OPPS/ASC Final Rule on November 2, 2023. You can read about changes to the Inpatient Only (IPO) Procedure List and ASC Coverage Procedure List (CPL) in a related article in this week’s newsletter. This article highlights additional topics that historically our clients have reached out to us to learn about.

OPPS Remedy for 340B-Acquired Drug Payment Policy

On July 7, 2023, CMS published a proposed rule, referred to as “remedy proposed rule” to address reduced payment amounts to 340B hospitals for CYs 2018 through 2022 and to comply with the statutory requirement to maintain budget neutrality. The “remedy proposed rule” proposed changes to the calculation of the OPPS conversion factor beginning in CY 2025.

The 340B final remedy was also issued on November 2^nd. In this final rule, CMS finalized their proposed methodology of estimating the reduction in drug payments to affected 340B covered entity hospitals in CY 2018 through September 27, 2022, and will make total lump sum payments in the amount of $9.004 billion.

CMS will be issuing instructions to the MACs to issue a one-time lump sum payment to the affected hospitals within 60 calendar days of the MAC’s receipt of the instructions.

Based on updated analyses, the final rule Addendum AAA was updated with new hospital-specific payment amounts and accounts for all payment activity that has happened since the proposed rule was issued. Updated claims data reflects that affected hospitals received approximately $10.6 billion less in 340B drug payments (including money that would have been paid by Medicare and money that would have come from the beneficiaries as copayments) than they would have for drugs provided in CY 2018 through September 27, 2022, had the 340B policy not been implemented.

“The amounts included in Addendum AAA are the amounts that hospitals will receive, except that payment amounts may be affected by MACs continuing to follow normal accounting processes for collecting repayment amounts stemming from provider-specific overpayment obligations, adjustments resulting from errors identified through the lump-sum technical correction process described below, as well as other unique situations such as provider bankruptcy or payment suspension, any of which may impact the provider’s net payment amount.”

Unfortunately, the lump sum payments do not include interest and CMS is following budget neutrality requirements to make these payments. This means that “beginning in CY 2026, we will reduce all payments for non-drug items and services to all OPPS providers, except new providers (hospitals with a CMS CCN effective date of January 2, 2018, or later), by 0.5 percent each year until the total estimated offset of $7.8 billion is reached. We currently estimate that the payment decrease will be completed after approximately 16 years. To implement this reduction and exception for new providers, we are finalizing the proposed regulation text changes at § 419.32(b)(1)(iv)(B) as proposed, except for changing the implementation date of the 0.5 percent reduction from CY 2025 to CY 2026.”

CMS notes in the 340B remedy final rule that “generally the impact of that annual 0.5 percent reduction to the OPPS conversion factor on individual providers, as well as categories of providers, will depend on the percentage of their OPPS payments that are conversion factor-based, and in most cases will be a decrease of slightly less than 0.5 percent of overall OPPS payments.”

Beneficiary Cost Sharing

CMS noted in the final rule that commenters overwhelmingly supported their proposed approach and rationale for accounting for beneficiary cost sharing. They finalized their “policy to account for beneficiary cost sharing as proposed. We will exercise our authority under section 1833(t)(2)(E) of the Act (42 U.S.C. 1395l(t)(2)(E)) to make adjustments “as necessary to ensure equitable payments,” to pay the full $9.0 billion difference, including $1.8 billion, an amount that is approximately equivalent to what affected 340B covered entity hospitals would have collected from beneficiaries for these 340B-acquired drugs if the 340B Payment Policy had not been in effect from CY 2018 through September 27, 2022, so that affected 340B covered entity hospitals are paid the approximate amount they would have been paid in full without application of the 340B Payment Policy.”

340B Modifiers “JG” and “TB”

The Inflation Reduction Act of 2022 expanded the provider types that must report one of these modifiers no later than January 1, 2024, to now include critical access hospitals, Maryland All-Payer or Total Cost of Care Model Hospitals, and Non-excepted off-campus provider-based departments (PBD).

In the CY 2023 OPPS/ASC final rule, CMS maintained the requirements that 340B hospitals report one of two modifiers, “JG” – Drug or biological acquired with 340B drug pricing program discount, reported for informational purposes, or “TB” – Drug or biological acquired with 340B drug pricing program discount, reported for informational purposes for select entities.

In the CY 2024 OPPS/ASC proposed rule, CMS notes they “now believe utilizing a single modifier will allow for greater simplicity, especially because both modifiers are used for the same purpose: to identify separately payable drugs and biologicals acquired under the 340B program.”

CMS is proposing that all 340B covered entity hospitals would report the “TB” modifier effective January 1, 2025, even if the hospital previously reported the “JG” modifier. The “JG” modifier will remain effective through December 31, 2024. Beginning January 1, 2025, the “JG” modifier would be deleted.

CMS notes hospitals currently using the “JG” modifier could choose to continue to use it in CY 2024 or choose to transition to the “TB” modifier during that year.