In the last I-10 Corner article we covered Part One of Musculoskeletal System in ICD-10-CM. For this week, Part Two will address the procedures for the Musculoskeletal System. For the PCS portion, we will cover some key points and guidelines that are necessary for you to assign the correct ICD-10-PCS codes.

For those of you who attended AHIMA’s ICD-10-CM/PCS training classes you already know the underlying meaning of the title. In ICD-10-PCS, this sentence helps us to identify the names of the seven characters and what they represent for a code in PCS. Notice below the sharp contrast between ICD-9 and ICD-10-PCS for a left total knee replacement:

ICD-9-CM: Total Knee Replacement, 81.54

ICD-10-PCS: Left Total Knee Replacement, with insertion of total knee prosthesis 0SRD0JZ

‍ICD-10-PCS for the Musculoskeletal System – Part 2

11 of the 31 Body Systems pertain to the MS System                  

• Muscles
• Tendons
• Bursae and Ligaments
• Head and facial bones
• Upper bones
• Lower bones
• Upper joints
• Lower joints
• Anatomical regions general
• Anatomical regions upper extremities
• Anatomical regions lower extremities Example of Root Operation Groups typically seen with Chapter 13
• Excision – Biopsy of muscle
• Detachment – Below knee amputation
• Division - Osteotomy
• Release – Carpal tunnel release
• Reattachment – Reattachment of hand
• Reposition – Fracture reduction
• Transfer – Tendon transfer
• Replacement – Total hip replacement
• Supplement – Placing a new acetabular liner in a previous hip replacement
• Revision – Re-cementing hip prosthesis
• Fusion – Spinal fusion
• Inspection – Diagnostic Arthroscopy
• laterality
• type and material the device is made of, i.e., synthetic substitute or autologous tissue substitute
• specific surface replaced in partial hip and knee replacements
• cemented vs. un-cemented

Arthroplasty of Hip and Knee

Often, the hip bearing surface was not known and was not reported. In ICD-10-PCS, you must know the type of surface for arthroplasty of the hips and knees in order to assign the correct procedure code.

You need to know:

• laterality
• type and material the device is made of, i.e., synthetic substitute or autologous tissue substitute
• specific surface replaced in partial hip and knee replacements
• cemented vs. un-cemented

ICD-10-PCS Coding Guideline

Conventions

A11

Many of the terms used to construct PCS codes are defined within the system. It is the coder’s responsibility to determine what the documentation in the medical record equates to in the PCS definitions. The physician is not expected to use the terms used in PCS code descriptions, nor is the coder required to query the physician when the correlation between the documentation and the defined PCS terms is clear.

Example: When the physician documents “partial resection” the coder can independently correlate “partial resection” to the root operation Excision without querying the physician for clarification.

B3. Root Operation

Overlapping Body Layers

B3.5

If the root operations Excision, Repair or Inspection are performed on overlapping layers of the musculoskeletal system, the body part specifying the deepest layer is coded.

Example: Excisional debridement that includes skin and subcutaneous tissue and       muscle is coded to the muscle body part.

Fusion Procedures of the Spine

B3.10a

The body part coded for a spinal vertebral joint(s) rendered immobile by a spinal fusion procedure is classified by the level of the spine (e.g. thoracic). There are distinct body part values for a single vertebral joint and for multiple vertebral joints at each spinal level.

Example: Body part values specify Lumbar Vertebral Joint, Lumbar Vertebral Joints, 2 or More and Lumbosacral Vertebral Joint.

B3.10b

If multiple vertebral joints are fused, a separate procedure is coded for each vertebral joint that uses a different device and/or qualifier.

Example: Fusion of lumbar vertebral joint, posterior approach, anterior column and fusion of lumbar vertebral joint, posterior approach, posterior column are coded separately.

B3.10c

Combinations of devices and materials are often used on a vertebral joint to render the joint immobile. When combinations of devices are used on the same vertebral joint, the device value coded for the procedure is as follows:

• If an interbody fusion device is used to render the joint immobile (alone or containing other material like bone graft), the procedure is coded with the device value Interbody Fusion Device
• If bone graft is the only device used to render the joint immobile, the procedure is coded with the device value Nonautologous Tissue Substitute or Autologous Tissue Substitute
• If a mixture of autologous and nonautologous bone graft (with or without biological or synthetic extenders or binders) is used to render the joint immobile, code the procedure with the device value Autologous Tissue Substitute

Examples: Fusion of a vertebral joint using a cage style interbody fusion device containing morsellized bone graft is coded to the device Interbody Fusion Device.

Fusion of a vertebral joint using a bone dowel interbody fusion device made of cadaver bone and packed with a mixture of local morsellized bone and demineralized bone matrix is coded to the device Interbody Fusion Device.

Fusion of a vertebral joint using both autologous bone graft and bone bank bone graft is coded to the device Autologous Tissue Substitute.

Release procedures

B3.13

In the root operation Release, the body part value coded is the body part being freed and not the tissue being manipulated or cut to free the body part.

Example:         Lysis of intestinal adhesions is coded to the specific intestine body part value.

Release vs. Division

B3.14

If the sole objective of the procedure is freeing a body part without cutting the body part, the root operation is Release. If the sole objective of the procedure is separating or transecting a body part, the root operation is Division.

Examples: Freeing a nerve root from surrounding scar tissue to relieve pain is coded to the root operation Release. Severing a nerve root to relieve pain is coded to the root operation Division.

B4. Body Part

Branches of body parts

B4.2

Where a specific branch of a body part does not have its own body part value in PCS, the body part is coded to the closest proximal branch that has a specific body part value.

Example: A procedure performed on the popliteus tendon is coded to the lower leg tendon body part.

Tendons, ligaments, bursae and fascia near a joint

B4.5

Procedures performed on tendons, ligaments, bursae and fascia supporting a joint are coded to the body part in the respective body system that is the focus of the procedure. Procedures performed on joint structures themselves are coded to the body part in the joint body systems.

Example: Repair of the anterior cruciate ligament of the knee is coded to the knee bursae and ligament body part in the bursae and ligaments body system.

Knee arthroscopy with shaving of articular cartilage is coded to the knee joint body part in the Lower Joints body system.

Skin, subcutaneous tissue and fascia overlying a joint

B4.6

If a procedure is performed on the skin, subcutaneous tissue or fascia overlying a joint, the procedure is coded to the following body part:

• Shoulder is coded to Upper Arm
• Elbow is coded to Lower Arm
• Wrist is coded to Lower Arm
• Hip is coded to Upper Leg
• Knee is coded to Lower Leg
• Ankle is coded to Foot

Fingers and toes

B4.7

If a body system does not contain a separate body part value for fingers, procedures performed on the fingers are coded to the body part value for the hand. If a body system does not contain a separate body part value for toes, procedures performed on the toes are coded to the body part value for the foot.

Example: Excision of finger muscle is coded to one of the hand muscle body part values in the Muscles body system.

ICD-10-CM Chapter 13 Musculoskeletal System – Part 1
In the last I-10 Corner article we covered Infectious and Parasitic Diseases. Our next chapter to review is the Musculoskeletal System which we will cover in two parts. Part one will cover ICD-10-CM and Part two will address ICD-10-PCS. In ICD-10-CM, we will highlight some changes we thought were important for you to be aware of. For instance, The Musculoskeletal System chapter received numerous code expansions partly due to ‘laterality’ being required for code assignment.

Example: Right Medial Epicondylitis

First, take a look below and see how the subchapters or blocks have expanded.

This chapter contains the following blocks:

M00-M02        Infectious Arthropathies

M05-M14        Inflammatory Polyarthropathies

M15-M19        Osteoarthritis

M20-M25        Other Joint Disorders

M26-M27        Dentofacial Anomalies [including malocclusion] and Other Disorders of Jaw

M30-M36        Systemic Connective Tissue Disorders

M40-M43        Deforming Dorsopathies

M45-M49        Spondylopathies

M50-M54        Other Dorsopathies

M60-M63        Disorders of Muscles

M65-M67        Disorders of Synovium and Tendon

M70-M79        Other Soft Tissue Disorders   

M80-M85        Disorders of Bone Density and Structure

M86-M90        Other Osteopathies

M91-M94        Chondropathies

New in Chapter 13

• Big code expansion in this chapter to identify type, site and laterality
• Clarifications for coding joint vs. specific affected bone (see coding guideline)
• Acute traumatic vs. chronic/recurrent conditions are defined with coding instructions
• Osteoporosis and Pathological Fracture information now included in ICD-10-CM Coding Guidelines
• Many codes relocated from other chapters in ICD-9-CM, i.e., Gout, Osteomalacia and Malocclusion
• Lots of other instructions such as:
• Use an external cause code
• Code first underlying disease
• Code also any associated underlying condition
• Use additional code to identify
• Code first poisoning due to drug or toxin
• Code first underlying neoplasm
• Use additional code to identify infectious agent
• Instructions for coding pathological fractures, needs 7th digit extension to identify episode of care (see below)
  Example:
  A Initial encounter for fracture
  D Subsequent encounter for fracture with routine healing
  G Subsequent encounter for fracture with delayed healing
  K Subsequent encounter for fracture with nonunion
  P Subsequent encounter for fracture with Malunion
  S Sequela
• Intraoperative and Postprocedural Complications of the Musculoskeletal System located within this chapter
• Acute traumatic fractures reassigned to Chapter 19 Injury, Poisoning and Certain Other Consequences of External Causes

ICD-10-CM Coding Guidelines

1. Site and laterality
   Most of the codes within Chapter 13 have site and laterality designations. The site represents the bone, joint or the muscle involved. For some conditions where more than one bone, joint or muscle is usually involved, such as osteoarthritis, there is a “multiple sites” code available. For categories where no multiple site code is provided and more than one bone, joint or muscle is involved, multiple codes should be used to indicate the different sites involved.
2. Bone versus joint
   For certain conditions, the bone may be affected at the upper or lower end, (e.g., avascular necrosis of bone, M87, Osteoporosis, M80, M81). Though the portion of the bone affected may be at the joint, the site designation will be the bone, not the joint.
3. Acute traumatic versus chronic or recurrent musculoskeletal conditions
   Many musculoskeletal conditions are a result of previous injury or trauma to a site, or are recurrent conditions. Bone, joint or muscle conditions that are the result of a healed injury are usually found in chapter 13. Recurrent bone, joint or muscle conditions are also usually found in chapter 13. Any current, acute injury should be coded to the appropriate injury code from chapter 19. Chronic or recurrent conditions should generally be coded with a code from chapter 13. If it is difficult to determine from the documentation in the record which code is best to describe a condition, query the provider.
4. Coding of Pathologic Fractures
   Seventh (7th) character A is for use as long as the patient is receiving active treatment for the fracture. Examples of active treatment are: surgical treatment, emergency department encounter, evaluation and treatment by a new physician. Seventh (7th) character D is to be used for encounters after the patient has completed active treatment. The other 7th characters, listed under each subcategory in the Tabular List, are to be used for subsequent encounters for treatment of problems associated with the healing, such as malunions, nonunions, and sequelae.
   Care for complications of surgical treatment for fracture repairs during the healing or recovery phase should be coded with the appropriate complication codes.
   See Section I.C.19. Coding of traumatic fractures.
5. Osteoporosis
   Osteoporosis is a systemic condition, meaning that all bones of the musculoskeletal system are affected. Therefore, site is not a component of the codes under category M81, Osteoporosis without current pathological fracture. The site codes under category M80, Osteoporosis with current pathological fracture, identify the site of the fracture, not the osteoporosis.
6. Osteoporosis without current pathological fracture
   Category M81, Osteoporosis without current pathological fracture, is for use for patients with osteoporosis who do not currently have a pathologic fracture due to the osteoporosis, even if they have had a fracture in the past. For patients with a history of osteoporosis fractures, status code Z87.310, Personal history of (healed) osteoporosis fracture, should follow the code from M81.
7. Osteoporosis with current pathological fracture
   Category M80, Osteoporosis with current pathological fracture, is for patients who have a current pathologic fracture at the time of an encounter. The codes under M80 identify the site of the fracture. A code from category M80, not a traumatic fracture code, should be used for any patient with known osteoporosis who suffers a fracture, even if the patient had a minor fall or trauma, if that fall or trauma would not usually break a normal, healthy bone.

Musculoskeletal System examples of why you need to brush up on your Anatomy and Physiology

Infectious Arthropathy - may also be referred to as Pyogenic or Septic Arthritis. Organisms invade the joint by:

• direct infection of joint; example: infected surgical hip wound
• indirect contamination; infection in bloodstream

Enteropathic Arthropathy - diseases of joints linked to gastrointestinal tract inflammation such as Inflammatory Bowel Disease or Crohn’s Disease.

Palindromic Rheumatism - is a sudden onset of inflammation in one or several joints. Lasts a few hours to a few days and is suddenly gone.

Dorsopathies - is a general term referring to conditions affecting the back or spine. Conditions such as Scoliosis, Spondylosis and Intervertebral disc disorders are included here.

Fragility Fracture -sustained with trauma no more than a fall from a standing height or less that occurs under circumstances that would not cause a fracture in a normal healthy bone.

Skeletal Fluorosis - this is excessive intake of fluoride causing the bones to become hardened and vulnerable to fractures.

In closing, the more you study this chapter the less you will feel overwhelmed. Once you do this, you will become familiar with the clinical information so that you can educate your physicians of what is required for more specific documentation.

Don’t forget to consult Coding Clinic for ICD-10-CM/PCS information!

Methicillin-resistent Staphylococcus Aureus (MRSA) Infection

MRSA is a very tough to treat infection caused by a strain of staph bacteria that has become resistant to commonly used antibiotics generally used to treat ordinary staph infections.

• Can be life threatening.
• MRSA infection can be contagious by:
• Person-to-person / skin-to-skin contact.
• Coming in contact with materials or surfaces touched by a MRSA infected person or carrier

• A “carrier” is a person that that harbors the organism (MRSA) without manifesting symptoms of the infection.
• A carrier (Z22.322) can transmit the MRSA infection.
• Requires “isolation” while being treated.
• Typically causes skin sores and infections such as:
• Abscess
• Boils
• Stys
• Ulcers
• Cellulitis
• Impetigo
• Carbuncles
• MRSA can quickly spread once the germ has entered into the body.
• Bones
• Joints
• Bloodstream (Sepsis - )
• Muscle, Fascia (Necrotizing Fasciitis)
• Organs
• Brain (Meningitis)
• Heart (Endocarditis)
• Lungs (Pneumonia)
• Kidneys (UTI associated with Foley Catheter)

Health Care-Associated MRSA (HA-MRSA)

• Affects people who have been treated in a health-care facility such as:
• Hospitals
• Nursing Homes
• Rehab facilities
• Dialysis center
• Physician’s office
• Commonly seen in patients with:
• Weakened immune system from:
• Illness
• Long term medication therapy
• Cancer treatment
• Surgical history within a year
• Lengthy admissions to hospitals and/or long-term care facilities
• Chronic Kidney Disease on hemodialysis
• History of IV drug use

Community-Associated MRSA (CA_MRSA)

• MRSA showing up in healthy people outside of a health care setting
• Healthy people who may also be at risk:
• Military
• Children at day-care
• Athletes
• Prison inmates
• People who share items such as towels and razors
• People who have gotten tattoos and/or piercings

Signs and Symptoms

• Non-healing wound
• Headache
• Fatigue
• Rash
• Fever and chills
• Low blood pressure
• Shortness of breath
• Chest pain
• Weakness

Treatment

MRSA is resistant to some antibiotics but is still a treatable condition. There are some kinds of antibiotics that still work.

• Treatment often starts with Bactrim and Vancomycin.
• Other antibiotics used are:
• Clindamycin
• Minocycline
• Tygacil
• Cubicin
• Zyvox
• Synercid
• Unfortunately, even with these medications, there is emerging antibiotic resistance developing.
• Antibiotics are not always necessary.
• With early detection, in cases of a skin abscess or boil caused by MRSA, an incision and drainage may be all that is necessary.

Selection and Sequencing of MRSA Codes

Coding Guidelines:

• Section I.C.1.e.1.a. – Combination Codes for MRSA Infection:   When a patient is diagnosed with an infection that is due to Methicillin Resistant Staphylococcus Aureus (MRSA), and that infection has a combination code that includes the causal organism (e.g., Sepsis, Pneumonia) assign the appropriate combination code for the condition (e.g., code A41.02, Sepsis due to Methicillin Resistant Staphylococcus Aureus or code J15.212, Pneumonia due to Methicillin Resistant Staphylococcus Aureus). Do not assign code B95.62, Methicillin Resistant Staphylococcus Aureus Infection as the cause of diseases classified elsewhere, as an additional code because the combination code includes the type of infection and the MRSA organism. Do not assign a code from subcategory Z16.11, Resistance to Penicillins, as an additional diagnosis.
• Section I.C.1.e.1.b. – Other Codes for MRSA Infection:   When there is documentation of a current infection (e.g., wound infection, stitch abscess, urinary tract infection) due to MRSA, and that infection does not have a combination code that includes the causal organism, assign the appropriate code to identify the condition along with code B95.62, Methicillin Resistant Staphylococcus Aureus Infection as the cause of diseases classified elsewhere for the MRSA infection. Do not assign a code from subcategory Z16.11, Resistance to Penicillins.
• Section I.C.e.1.c. – Methicillin Susceptible Staphylococcus Aureus (MSSA) and MRSA Colonization:   The condition or state of being colonized or carrying MSSA or MRSA is called colonization or carriage, while an individual person is described as being colonized or being a carrier. Colonization means that MSSA or MRSA is present on or in the body without necessarily causing illness. A positive “MRSA screen positive” or “MRSA nasal swab positive”.
• Assign code Z22.322, Carrier or suspected carrier of Methicillin Resistant Staphylococcus Aureus, for patients documented as having MRSA colonization. Assign code Z22.321, Carrier or suspected carrier of Methicillin Susceptible Staphylococcus Aureus, for patient documented as having MSSA colonization. Colonization is not necessarily indicative of a disease process or as the cause of a specific condition the patient may have unless documented as such by the provider.

• Section I.C.1.e.1.d. – MRSA Colonization and Infection:   If a patient is documented as having both MRSA colonization and infection during a hospital admission, code Z22.322, Carrier or suspected carrier of Methicillin Resistant Staphylococcus Aureus, and a code for the MRSA infection may both be assigned.

Methicillin-susceptible Staphylococcus Aureus (MSSA) Infection

Another commonly known infection caused by the staph bacteria is Methicillin-susceptible Staphylococcus Aureus (MSSA). MSSA is able to be treated with most penicillin based antibiotics and has yet become resistant to the more common antibiotics enabling the treatment to be cleared up easier than it would be if it was resistant in the case of MRSA.

MSSA can be as serious as MRSA. Signs and symptoms are the same.

The implementation date of ICD-10-CM/PCS is fast approaching. ICD-10-CM/PCS will require coders to possess an in-depth knowledge and understanding of anatomy & physiology and pathophysiology.   Coders’, who are well-versed on how a body in both the healthy state as well as during the disease process should function, will be better prepared to query providers for clarification when additional documentation is required.  In turn, a coder will be able to make appropriate correlations when reviewing documentation and be able to avoid needless queries.

Sepsis, Severe Sepsis and Septic Shock

In ICD-10-CM, there are some terminology changes and revisions. An example in Chapter 1 is that the term Sepsis has replaced Septicemia.

Sepsis is a potential life threatening disease in which the body has a reaction to the presence of pathogenic organisms or toxins that have been released in the bloodstream and tissues.

• Also call “blood poisoning”.
• Patients with Sepsis will appear very sick.
• Diagnosis based on clinical signs and symptoms of infection or systemic inflammation and not on location of infection.
• Sepsis can be diagnosed without positive blood cultures especially when the patient has recently been treated with antibiotics.
• Signs and symptoms can be different from person to person.
• Elderly 80 year old female with UTI may have fever, tachycardia with an increase in white blood count
• A 3 year old child with appendicitis may have low body temp and low white count.
• The same signs and symptoms for Sepsis can also be caused by other disorders.

Coders should never code Sepsis based solely on clinical signs and symptoms alone. Provider clarification and documentation is imperative for the correct code assignment.

Note: When coding Sepsis, it is very important to read the Coding Guidelines and to stay abreast with the ever-changing quarterly updates.

Sepsis has 3 stages. Each stage is indicative of a higher level of severity.

1. Sepsis:     Coding Guideline – Section I.C.1.d.1.a.
2. Assign the appropriate code for the underlying systemic infection showing the type of causal organism. Example:   E coli Sepsis - A41.51.
3. Assign code A41.9 for Sepsis without a specified organism documented.
4. Signs and Symptoms – Patient must exhibit at least 2 of the following:
5. Fever above 100.4 or below 95.
6. Heart rate (tachycardia) higher than 90 beats per minute.
7. Respiratory rate higher than 20 breaths per minute or PaCO2<32 mmHg (4.3 kPa)
8. Confirmed or probable infection.
9. Shaking chills.
10. Leukocytosis
11. Greater than 10% immature bands
12. Hemorrhagic skin rash
13. Hypotension
14. The term “Urosepsis” is not to be considered synonymous with “Sepsis”.
15. There will no longer be a default code for Urosepsis.
16. Provider must be queried for clarification on whether the patient has Sepsis and/or UTI.
17. Severe Sepsis:     Coding Guideline – Section I.C.1.d.1.b.
18. Sepsis with an associated acute organ dysfunction/failure.
19. Coding Guideline – Section I.C.1.d.1.a.iv
20. Documentation must indicate that the acute organ dysfunction is associated with the Sepsis.
21. Query provider if documentation does not clearly show whether the acute organ dysfunction is associated to Sepsis or another condition.
22. Requires a minimum of two codes:
23. Code for underlying systemic infection.
24. Following code from subcategory R65.2.
25. Additional code should also be assigned to identify specific acute organ dysfunction/failure.
26. Patient’s usually treated in ICU.
27. Signs and Symptoms – Patient must exhibit at least 2 of the signs/symptoms listed above and at least one of the following:
28. Significant decrease in urine output.
29. Altered mental status (AMS).
30. Decrease in platelet count.
31. Difficulty breathing.
32. Abdominal pain.
33. Acidosis
34. Nausea and vomiting
35. Diarrhea
36. Cold, clammy and pale skin
37. Septic Shock:     Coding Guideline – Section I.C.1.d.2.
38. Severe Sepsis with extreme hypotension lasting for more than one hour without the return to normal pressure following adequate IV fluid infusion or the need for vasopressors/inotropes to maintain blood pressure.
39. Code for the underlying systemic infection should be sequenced first.
40. Assign following code R65.21 – Severe Sepsis with Septic Shock.
41. Severe Sepsis with Septic Shock must be assigned if Septic Shock is documented in the medical record, even if the term Severe Sepsis is not documented.

Sepsis due to a Post-procedural Infection:     Coding Guideline – Section I.C.1.d.5.

• Code assignment is based on provider documentation clarifying a relationship between the infection and the procedure.
• A code for the post-procedure infection should be assigned first – Example:
• T83.51 - Infection and Inflammatory Reaction due to Indwelling Urinary Catheter
• T80.21 – Infection due to Central Venous Catheter
• Appropriate code from subcategory R65.2 should be assigned if patient is diagnosed with Severe Sepsis along with a code to identify the associated acute organ dysfunction.

Patients at Risk

• Elderly
• Very young babies
• Diabetics
• Recently hospitalized and/or recent invasive surgical procedures
• With wounds or injuries, such as burns
• Weakened immune systems secondary to illnesses and/or drug therapy

Common Sources of Infection

• Urinary Catheters
• Surgical incisions
• Open wounds such as pressure ulcers, burns etc.
• Invasive devices such as IV catheters, breathing tubes etc.
• Surgical drains
• Prosthetic devices

Common Body Sites Where Infections May Start – (Examples)

• Bones – (Diabetics with Osteomyelitis)
• Bloodstream
• Intestines – (Diverticulitis, Peritonitis)
• Kidneys – (Urinary Tract Infection, Pyelonephritis)
• Lungs – (Pneumonia)
• Pancreas – (Pancreatitis)
• Skin – (Cellulitis, Pressure Ulcers)

The implementation date of ICD-10-CM/PCS is fast approaching. ICD-10-CM/PCS will require coders to possess an in-depth knowledge and understanding of anatomy & physiology and pathophysiology.   Coders’, who are well-versed on how a body in both the healthy state as well as during the disease process should function, will be better prepared to query providers for clarification when additional documentation is required.  In turn, a coder will be able to make appropriate correlations when reviewing documentation and be able to avoid needless queries.

The Office of Inspector General (OIG) recently released the report Medicare Incorrectly Paid Hospitals for Beneficiaries Who Had Not Received 96 or More Hours of Mechanical Ventilation. In fact, the report indicates that in the calendar years 2009 – 2011, Medicare overpaid hospitals $7.7 million.

Background

The OIG has done prior hospital compliance reviews of claims with MS-DRGs requiring 96 or more hours of mechanical ventilation. In past reviews the OIG found erroneous claims and as such this review was performed to determine whether payments made to hospitals for MS-DRGs requiring 96 or more hours of mechanical ventilation were correct. Hospitals use procedure code 96.72 (Continuous invasive mechanical ventilation for 96 consecutive hours or more) to identify these patients. This review focused specifically on two MS-DRGs:

• MS-DRG 207: Respiratory System Diagnosis with Ventilator Support 96+ Hours and
• MS-DRG 870: Septicemia or Severe Sepsis with Mechanical Ventilation 96+ Hours.

Audit by the Numbers

• $12,764,239: The amount of Medicare Part A payments covered in this audit.
• 290: The number of hospitals included in this audit.
• 377: The number of inpatient claims that were selected as at risk for billing errors.
• 4 days or less: This audit reviewed claims where the length of stay was 4 days or less.
• 14: The number of records where the Medicare payment was correct.
• 363: The number of records where the Medicare payment was incorrect due to the beneficiary not receiving 96 or more hours of mechanical ventilation.
• $7,714,825: The overpayments made by Medicare to the hospitals

As part of the audit process the OIG had the hospitals conduct an internal review of the claims to determine if the services had been billed correctly. The OIG also requested that the hospital provide them with the “itemized bills and medical record documentation, including timelog for the mechanical ventilation and summary of the inpatient stay to determine whether the beneficiaries had received 96 or more hours of mechanical ventilation.”

The report indicates that “the hospitals confirmed that these claims were incorrectly billed and generally attributed the errors to incorrectly counting the number of hours that beneficiaries had received mechanical ventilation or to clerical errors in selecting the appropriate procedure code.”

Centers for Medicare and Medicaid Services (CMS) Response and Action Plan

The OIG found that CMS did not have controls in place to identify the incorrectly paid claims. Since this review, CMS “implemented a new length-of-stay edit for continuous invasive mechanical ventilation for 96 consecutive hours or more. With this edit, effective October 1, 2012, claims found to have procedure code 96.72 and a length of stay fewer than 4 days are returned to the provider for validation and resubmission.”

Is Correct Coding of Ventilator Hours still on the Radar?

Since this review focused on 2009 through 2011 calendar year claims and an edit was put in place as a control to identify incorrectly paid claims, you may be thinking that this should no longer be an issue. However, other Contractors continue to review and or monitor correct coding of ventilator hours. Before we walk through a timeline of who is reviewing this issue it is important to note that most reviewers have expanded their efforts beyond MS-DRGs 207 and 870 to also include the following MS-DRGs:

• MS-DRG 003: Ecmo or Tracheostomy with Mechanical Ventilation 96+ Hours or Principal Diagnosis Except Face, Mouth and Neck with Major O.R.
• MS-DRG 004: Tracheostomy with Mechanical Ventilation 96+ Hours or Principal Diagnosis Except Face, Mouth and Neck without Major O.R.
• MS-DRG 927:Extensive Burns or Full Thickness Burns with Mechanical Ventilation 96+ Hours with Skin Graft
• MS-DRG 933: Extensive Burns or Full Thickness Burns with Mechanical Ventilation 96+ Hours without Skin Graft

Timeline of Review Efforts around Correct Coding of Ventilator Hours:

• Medicare Quarterly Compliance Newsletter October 2011: In the Volume 2, Issue 1 - October 2011 newsletter the CMS reported that Recovery Auditors reviewed MS-DRGs 003, 004, 207, 870, 927 and 933 due to Providers not adding the correct number of Ventilator hours during an inpatient admission. This Newsletter provides examples of their findings and education resources for hospitals.

• Cahaba GBA, the Medicare Administrative Contractor (MAC) for Alabama, Georgia and Tennessee completed a widespread probe review of MS-DRG 270 and posted the findings to their website on November 14, 2011. Their focus was on coding accuracy and medical necessity for acute inpatient hospitalization. One issue identified was that “documentation did not confirm 96 consecutive hours on ventilator support.” They took no further action as a result of this review but continue to monitor utilization through data analysis to see if further reviews are needed.

• The Program for Evaluating Payment Patterns Electronic Report (PEPPER) is now into their 12th Edition of the Short-Term Acute Care Hospitalizations Users Guide. Ventilator Support has been an at risk target since their 6th Edition Users Guide. Internally, providers can view their report to see if they are an outlier and follow the audit recommendations in the report.

• In the 2013 OIG Work Plan, the OIG indicated that “We will review Medicare payments for mechanical ventilation to determine whether the DRG assignments and resultant payments were appropriate. We will review selected Medicare payments to determine whether patients received fewer than 96 hours of mechanical ventilation. Mechanical ventilation is the use of a ventilator or respirator to take over active breathing for a patient. CMS requires that claims be completed accurately to be processed correctly and promptly. For certain DRG payments to qualify for Medicare coverage, a patient must receive 96 or more hours of mechanical ventilation.”

As you can see this is certainly not a new issue and hospitals need to remain vigilant in their efforts to correctly code ventilator hours.

This month MMP will focus on some of the important changes and guidelines covering Chapter One “Certain Infectious and Parasitic Diseases”.

Chapter 1 is divided into 22 separate blocks covering two alpha characters A00-B99 and includes:

• Diseases generally recognized as communicable or transmissible as well as a few diseases of unknown but possibly infectious origin.

Type I Excludes:

• Certain localized infections – refer to body system related chapters.
• Influenza and other acute respiratory infections (J00-J22)

Type 2 Excludes:

• Carrier or suspected carrier of infectious disease (Z22.-)

A separate subchapter was created for “Infections with a Predominantly Sexual Mode of Transmission” (A50-A64) to appropriately group these type diseases together:

• Human Immunodeficiency Virus (HIV) is excluded in this range of codes.

For cases with infections shown to have an associated drug resistance, code Z16 should be assigned in addition to the infection code to show the associated drug resistance.                      

• Coding Guideline I.C 1.c. – Infections Resistant to Antibiotics:  Many bacterial infections are resistant to current antibiotics. It is necessary to identify all infections documented as antibiotic resistant.

Streptococcal Sore Throat has been relocated from Chapter 1 to Chapter 10 – Diseases of the Respiratory System.

Tuberculosis (TB):  

• ICD-10-CM will not ask for information denoting how the disease was identified.
• The codes for Tuberculosis have been restructured and consolidated. Assignment is now based on anatomical site or type.

Intestinal Infections:

• Codes will now identify type of infection.
• Viral
• Bacterial
• Fungal or parasitic/amebic
• Options available for “Other “ and “Unspecified”

Categories B95.0-B99.9 are supplementary codes to identify the infectious agent(s) in diseases classified elsewhere in which there is no organism identified as part of the infection code.

• Refer to Coding Guideline I.C.1.b.

Human Immunodeficiency Virus (HIV) Infections

HIV is the virus that can lead to AIDS (Acquired Immunodeficiency Syndrome).   People with this illness are much more vulnerable to infections due to the attack and alteration to their immune system. This is prone to get worse as the disease progresses. The human body is not capable of fighting off this virus. Once a person is infected with HIV, it is an affliction for the rest of their life.

HIV is found in the body fluids of an infected person and can be transmitted:

• From one person to another through blood-to-blood and/or sexual contact.
• Newborn infants can acquire HIV:
• During pregnancy
• Through delivery
• Through breast feeding
• Blood transfusion
• Sharing hypodermic needles

There is a subcategory and four codes to classify the HIV virus in ICD-10-CM.

B20 - Human Immunodeficiency Virus (HIV) disease

Assign code B20 as the principal diagnosis when a patient is admitted with an HIV-related condition. An additional diagnosis code should be used to identify all reported manifestations of HIV infection.

• Refer to Coding Guideline I.C.1.a.2.a.
• Code only confirmed cases of HIV infection.
• Confirmation does not require a positive serology or culture for HIV. The physician’s diagnostic statement is sufficient.
• Refer to Coding Guideline I.C. 1.a.1.
• People with HIV can acquire many infections that are called “Opportunistic Infections” or OIs.

Includes:

• Acquired Immune Deficiency Syndrome (AIDS)
• AIDS-related Complex (ARC)
• HIV Infection, Symptomatic

Excludes Type 1:

• Asymptomatic Human Immunodeficiency Virus (HIV) Infection Status (Z21)
• Exposure to HIV virus (Z20.6)
• Inconclusive Serologic Evidence of HIV (R75)

Z21 - Asymptomatic Human Immunodeficiency Virus (HIV) Infection Status

Code Z21 is used for reporting a patient diagnosed with a positive HIV status but has never been diagnosed with any type of manifestation or OI.

• Includes HIV positive NOS
• Once a patient has developed an HIV-related OI, the patient should always be assigned code B20 for any future admission/encounter.
• Code Z21 should never be assigned again for a patient diagnosed with HIV/AIDS even if there is no infection or HIV related condition during that present admission.
• Codes B20 and Z21 should never be assigned together during the same admission.

R75 - Inconclusive laboratory evidence of Human Immunodeficiency Virus (HIV)

• An inconclusive serology test, but no definitive diagnosis or manifestation of the HIV infection.

Z20.6 - Exposure to HIV Virus

This code is assigned only when a patient has been exposed or may have come in contact with the HIV virus.

Some Common HIV Infections:   (this list is not all or inclusive)

• Pneumocystis pneumonia (PCP) - Serious infection which causes inflammation and fluid buildup in the lungs.
• Cytomegalovirus - An opportunistic infection which takes advantage of a patient’s weakened immune system.
• Tuberculosis (TB) - Leading cause of death for people infected with HIV.
• Mycobacterium Avium Complex (MAC) - Usually happens only after a patient has been diagnosed with AIDS and when their CD4 cell counts drop below 50.
• Dementia - AIDS dementia is caused by the HIV virus itself, not by the opportunistic infections.
• AIDS Wasting Syndrome - Occurs when a patient with AIDS has lost at least 10% of their body weight -- especially muscle. The patient could experience at least 30 days of diarrhea, extreme weakness and fever that's not related to an infection.
• Non-Hodgkin’s Lymphoma - As a result of a weakened immune system, a patient is prone to develop certain cancers.
• Lipodystrophy - Also known as “fat redistribution”.   This is when the body has problems in the way it produces, uses, and stores fat.
• Kaposi’s Sarcoma (KS) - Type of cancer affecting mainly the skin, mouth, and lymph nodes (infection-fighting glands). Other organs such as the lungs and gastrointestinal tract can be affected as well.

A list of Meds currently available in the US

‍Note: When coding the HIV Disease and Sepsis, it is very important to read and familiarize yourself with the Coding Guidelines. 

We are now into the second day of the Centers for Medicare and Medicaid Services (CMS) 2014 Fiscal Year. For those that were unable to listen to the CMS Special Open Door Forum (ODF) this past Thursday September 26th, CMS appeared to have heard and has responded to the medical community’s concerns around the education and implementation of the new 2-Midnight Benchmark for inpatient admissions and the Physician Certification of all inpatient admissions.

Clarification of CMS Inpatient Hospital Policy, Why Now?

On the same day as the ODF, CMS also released a letter to the American Hospital Association (AHA). In both this letter and during the ODF, CMS indicated that they have been facing “pressures” that include:

• “An increase in the average length of observation stays;
• An increase in the Comprehensive Error Rate Testing (CERT) error rate for short inpatient stays;
• An increase in the number of inpatient appeals; and
• Requests from the hospital industry requesting clarification on inpatient review policy.”

The two year conversation around these “pressures” between CMS and the hospital industry are what prompted the implementation of the 2-Midnight Benchmark and Physician Certification process. CMS announced that the next three months (October 1, 2013 – December 13, 2013) will be a transition period where they will monitor the impact of the changes to ensure that they result in the best interest for Medicare beneficiaries. Further, they announced a New Probe and Education Program.

New Probe and Education Program

This new program will begin with dates of admission on or after October 1, 2013 through December 31, 2013. Specific instructions for Contractors include the following:

• Medicare Administrative Contractors (MACs)
• MACs will shift their pre-payment focus to admissions on or after October 1st through December 31st with “0” or “1” midnight lengths of stay.
• The focus of these reviews will be to “determine the medical necessity of the patient status in accordance with the two midnight benchmark.”
• The Pre-payment Probe limit has been set at 10-25 claims per hospital.
• If a MAC completes a probe and finds no issues they will “cease further such reviews for that hospital from October – December 2013, unless there are significant changes in billing patterns for admissions.”
• If a MAC does identify issues, education will be provided to the hospital and then the MAC will conduct further follow-up as necessary.
• Since these will be pre-payment reviews, a hospital could re-bill any denied claims in accordance with the Part A to Part B rebilling Final Rule.
• MACs will use their review findings to determine a hospital’s compliance with the new inpatient rules and provide feedback to CMS for development of joint education and guidance.

• Recovery Auditors (RAs)
• During this same 90 days, “CMS will not permit Recovery Auditors to review inpatient admissions of one midnight or less that begin on or after October 1, 2013.”
• The RA Pre-payment Demonstration will be suspended during the 90 day period for the 11 states that are participating in this demonstration (FL, CA, MI, TX, NY, LA, IL, PA, OH, NC, and MO).
• RAs will continue pre-payment reviews for Therapy Caps.

• Caution:
• CMS reminds providers that “physicians should make inpatient admission decisions in accordance with the 2 midnight provisions in the final rule. If at any time there is evidence of systematic gaming, abuse or delays in the provision of care in an attempt to surpass the 2-midnight presumption could warrant medical review.”
• During this transition period MACs can continue to perform coding validation reviews.
• The CERT contractor, Zone Program Integrity Contractors (ZPICs), Office of Inspector General (OIG), etc. are not limited by this 90 day time period and can continue to pick any claims for review.
• Contractor reviews specifically supporting the medical necessity of a surgery (i.e. total knee replacement) and correct coding reviews can continue during this time.

Dress Rehearsal

Moving forward, CMS has set up an Inpatient Hospital Reviews webpage on their website under Medical Review and Education and encourages hospitals to check this site frequently for updates.

Hospitals should take this time to use the next three months as a dress rehearsal to continue with staff education, proceed with your plans to be compliant with the 2-Midnight Benchmark and develop processes to ensure completion of the Physician Certifications prior to beneficiaries being discharged.

2014 IPPS Final Rule Resources:

Link to the Final Rule:  http://www.gpo.gov/fdsys/pkg/FR-2013-08-19/pdf/2013-18956.pdf

Link to September 5, 2013 Guidance - Hospital Inpatient Admission Order and Certification:  http://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/AcuteInpatientPPS/Downloads/IP-Certification-and-Order-09-05-13.pdf

Link to MLN Matters: SE1333 – Temporary Instructions for Implementation of Final Rule 1599-F for Part A to Part B Billing of Denied Hospital Inpatient Claims

 http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/SE1333.pdf

Link to CMS Open Door Forums webpage:  http://www.cms.gov/Outreach-and-Education/Outreach/OpenDoorForums/ODFSpecialODF.html

One thing that we all continue to hear about the transition to ICD-10-CM is the increased specificity of the codes. Asthma is one example of the increased specificity with ICD-10-CM. ICD-9-CM used an older classification for Asthma that is no longer relevant for treatment. Over the years the guidelines and classifications of Asthma have been revised. The latest update was released in 2007 by the National Asthma Education and Prevention Program which is coordinated by the National Heart, Lung and Blood Institute (NHLBI). ICD-10-CM has incorporated the classifications listed below into the new code set.

• Mild Intermittent Asthma (J45.2_)
• Symptoms occur less than two days per week and no interference with regular activities.
• Fewer than 2 days a month of night time symptoms
• Lung Function Tests (LFTs) are normal when they are not having an asthma attack
•  Mild Persistent Asthma(J45.3_)
• Symptoms occur more than 2 days per week, but not every day and there is interference of daily activities.
• Three to four times a month of night time symptom occurrences
• LFTs are normal when not having an asthma attack
•  Moderate Persistent Asthma (J45.4_)
• Symptoms occur daily requiring inhaled asthma medication and may restrict physical activity
• Night time symptoms occur more than once a week, but not every day
• Abnormal LFTs
• Severe Persistent Asthma (J45. 5_)
• Symptoms occur throughout the day with frequent severe attacks limiting the ability to breathe and perform physical activities
• Night time symptoms sometimes occur every night
• Abnormal LFTs

It is interesting to note that in ICD-9-CM Extrinsic Asthma codes to 493.0x and Intrinsic Asthma codes to 493.1x. However, in ICD-10-CM both Extrinsic/Intrinsic (allergic and nonallergic) are assigned to J45.909, Unspecified Asthma.

A discussion needs to take place with your physicians who treat Asthma patients to make them aware of the updated classifications so their documentation will reflect the medical complexity of their patients. Talking to your physicians now will hopefully reduce the amount of queries in the future.

Below are the links that contain the clinical information and updated guidelines for Asthma.

 http://www.nhlbi.nih.gov/guidelines/asthma/asthsumm.pdf

 http://www.webmd.com/asthma/tc/classification-of-asthma-topic-overview

Over the years the American Health Information Management Association (AHIMA) has provided guidance on when and how to query for additional health record documentation in a compliant manner. They have recently published a new practice brief on “Guidelines for Achieving a Compliant Query Process” that augments and where applicable, supersedes prior AHIMA guidance on queries. MMP, Inc. encourages coders and clinical documentation specialists to read the AHIMA article for complete guidance and some excellent examples of compliant and non-compliant queries.

Key Points about Queries

The AHIMA article defines the purpose of a query as follows: “The desired outcome from a query is an update of a health record to better reflect a practitioner’s intent and clinical thought processes, documented in a manner that supports accurate code assignment.”

• Queries should be used to clarify documentation in the medical record for accurate code assignment, such as when
• Information is ambiguous, incomplete, or conflicting,
• Clinical indicators are not related to a specific condition,
• Clinical indicators to support a documented diagnosis are missing, or
• Greater specificity is needed.
• All queries must be accompanied by the relevant clinical indicator(s) that justify the need for the query. These indicators should be derived from the specific patient’s current episode of care and may contain elements from any part of the current medical record.
• Verbal queries should contain the same information and be in the same format as written queries.
• Queries should not indicate the impact on reimbursement or provider profiles.
• Queries should not be leading. A leading query is one that is
• Not supported by clinical indicators in the medical record and/or
• Directs or “leads” a provider to a specific diagnosis or procedure.

Query Formats

Although open-ended queries are preferred, “yes/no” queries and multiple choice queries are acceptable under certain circumstances.

Yes/no queries:

• Are appropriate for example in
• determining if a documented condition was present on admission (POA),
• substantiating a diagnosis that is already present in the medical record,
• establishing a cause and effect relationship, or
• resolving conflicting documentation.
• Should include additional options besides “yes” and “no” such as “clinically undetermined”, “other”, and “not clinically significant”.
• Should not be used to document a condition/diagnosis that is not already documented in the medical record, i.e. a new diagnosis based on clinical indicators.

Multiple choice queries:

• Are appropriate for example to document greater specificity.
• Should include clinically significant and reasonable options as supported by the clinical indicators.
• Should include additional options such as such as “clinically undetermined”, “other”, and “not clinically significant”.
• Should allow the addition of free text by the provider.

Note: It is acceptable to include a new diagnosis as an option in a multiple choice list if supported by the clinical indicators, since other options including “other” and free text are also available.

Handling Missing Clinical Indicators

Is a query appropriate when a diagnosis is documented that does not appear to be supported by clinical indicators or should this type of conflict be addressed through the facility’s escalation policy? This is something your hospital will have to decide how to handle. CMS recommends that all facilities have an escalation policy that may include referral to a physician advisor, chief medical officer, or other administrative personnel. Even if you use queries in some of these situations, escalation will be needed for more complex situations, for unanswered queries and to address any concerns regarding queries. An example of a query from the brief that addresses documented conditions without clinical indicators is:

QUERY: “Please review the laboratory section of the present record to confirm your discharge diagnosis of hypernatremia. Laboratory findings indicate a serum sodium of 120 mmol/L.”

Should the Query Be Part of Your Medical Record?

Your facility should have internal policies that address query retention and whether the query is to be a part of the patient’s permanent medical record or stored as a separate business document. Either way, remember that the medical record should include the clinical rationale for all diagnoses. Also, capturing the content of the query and the provider’s response supports the sequence of events so that documentation does not appear out of context.

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Background

As part of the Deficit Reduction Act of 2005 (DRA), hospitals were required to begin reporting whether or not diagnoses were Present on Admission (POA) on or after October 1, 2007.

General POA Requirements:

• POA indicator is required for all claims involving Medicare inpatients admitted to general IPPS acute care hospitals.
• POA is defined as present at the time the order for inpatient admission occurs – conditions that develop during an outpatient encounter, including emergency department, observation, or outpatient surgery, are considered POA.
• The POA indicator is assigned to the principal diagnosis and secondary diagnoses.
• Inconsistent, missing, conflicting or unclear documentation must be resolved by the provider.
• POA indicator is not reported if a condition would not be coded and reported based on Uniform Hospital Discharge Data Set definitions and current Official Guidelines.
• CMS does not require a POA indicator for the external cause of injury code unless it is being reported as an “other diagnosis.”

(Source: CMS POA Fact Sheet)

Office of Inspector General (OIG) November 23, 2012 Report: Assessment of Hospital Reporting of Present on Admission Indicators on Medicare Claims.OEI-06-09-00310

The OIG recently released a report that assessed POA indicator accuracy and the nature of any miscoding. As background to this review the OIG indicated that Section 5001 (c) of the Deficit Reduction Act of 2006 mandated that hospitals would not receive increased Medicare reimbursement for certain conditions that develop during a hospitals stay that were not present on admission. These conditions are referred to as “hospital-acquired conditions” and the list of conditions is updated annually. Assigning POA indicators “provides a necessary framework” for making the determination of whether or not a diagnosis is a “hospital-acquired condition.”

For the report, the OIG utilized contracted certified coders that reviewed medical records and “documented all misreported POA indicators and described circumstances that may have contributed to the errors.”

The OIG found that “hospital coders incorrectly reported 3 percent of the 5,491 POA indicators reviewed, resulting in the presence of at least one incorrect indicator on 129 claims (18 percent).” There were three main groups of errors identified and include:

• Twenty-One Percent were related to the assessment of developing or chronic conditions
• Conditions that were developing at the time of admission with misreported POA indicators included systemic inflammatory response syndrome (SIRS), septic shock, blood infections, urinary tract infections, pneumonia, pressure ulcers, constipation, and malnutrition.
• Chronic conditions with misreported POA indicators included diabetes and patient’s experiencing an exacerbation of a chronic condition such as congestive heart failure.

• Thirty-Two Percent involved errors in assigning POA indicators to exempted conditions.
• In these cases the hospital coder either assigned a POA indicator code when he/she should have identified the diagnosis as exempt or coded a diagnosis as exempt when it was not on the published list of exemptions and should have been assigned POA indicators.

• Forty-Seven Percent involved other reporting errors not associated with developing or chronic conditions or with exemptions. Specific examples in the report include:

• The OIG coders found documentation contradicting the POA designation.
• Medical record review clearly indicated the presence or absence of a diagnosis at the time of admission. “This suggests that hospital coders may have failed to notice or disregarded the information necessary to make an accurate POA assessment.”
• Physician’s documentation not clearly indicating when a condition developed.
• Other issues such as a diagnosis changing during the hospitalization.

The OIG concluded that the 3-percent error rate is relatively low and no recommendations were made. At MMP we believe that it is important to point out that in their conclusion, the OIG indicates that “POA indicators provide an opportunity for monitoring hospital quality of care and are critical to CMS’s efforts to link payment to quality, but they must be accurate to serve these purposes. Encouraging hospitals to assess POA reporting practices related to developing conditions and exemption codes, and to retrain staff as needed, could help to ensure accuracy.”