Knowledge Base Category -

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.

 

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

‍

Hospitals are facing significant changes with the implementation of the 2014 IPPS Final Rule. Beyond medical necessity guidance, physician certification and recertification for a Part A inpatient admission and the Part A to Part B rebilling, the National Uniform Billing Committee (NUBC) developed and approved new discharge status codes that were finalized for use in the Final Rule.

An interesting twist is that these codes are to be used specifically for DRG 280 (Acute Myocardial Infarction, Discharged Alive with MCC), DRG 281 (Acute Myocardial Infarction, Discharged Alive with CC), DRG 282 (Acute Myocardial Infarction, Discharged Alive without CC/MCC) and DRG 789 (Neonates, Died or Transferred to Another Acute Care Facility).

DRGs 280, 281 and 282:

The finalized rule added one new code for this DRG group.

• New Code: 69 - Discharged/transferred to a designated disaster alternative care site
• Purpose: “Is to identify those patients diagnosed with an acute myocardial infarction (AMI) who were discharged/transferred to a designated disaster alternative care site alive.”
• Final Rule Comments: Most people that commented on this proposal were supportive of adding this new code and anticipate that it will be used infrequently.

The 15 remaining discharge status codes were proposed and finalized to identify planned readmissions after an AMI index admission. The new codes will replace codes already in place. In response to a comment CMS clarified that “at this time, these new discharge status codes are not related in any way to the Hospital Readmission Reduction Program and will not be taken into account in the readmission measures for that program.” The following table is a crosswalk from the current code to the new code. (This table can be found in the Final Rule on pages 50533 – 50534).

‍DRG 789:

Three new discharge status codes have been added to this DRG “to identify neonates that are transferred to a designated facility with a planned acute care hospital inpatient readmission.” The new codes can be found on page 50538 of the final rule and include:

Suggestions to prepare for the new discharge status codes:

• Work with your IT Department to ensure that your systems have been updated to reflect these changes,
• Provide physician education to help ensure that there is clear documentation in the Index admission that he/she is planning on readmitting the patient; and
• Educate HIM and Case Management staff.

The Medicare Hospital Conditions of Participation (CoPs) allow stamped signatures but Medicare conditions of payment do not allow stamped signatures and now there is an exception to the conditions of payment that does allow stamped signatures. Are you confused yet? Let’s see if we can sort this out.

Section 3.3.2.4 of the Medicare Program Integrity Manual addresses signature requirements for Medicare medical review purposes. This section states:

“For medical review purposes, Medicare requires that services provided/ordered be authenticated by the author. The method used shall be a handwritten or electronic signature. Stamped signatures are not acceptable.” (emphasis added)

This means that for services to be approved for payment by Medicare, they must contain a legible handwritten or electronic signature. Stamped signatures are generally not acceptable for Medicare payment purposes. However, under the Rehabilitation Act of 1973 a stamped signature will be accepted in the case of an author with a physical disability.

Change Request 8219 (MLN Matters Article MM8219) clarifies that CMS will permit the use of a rubber stamp for signature when the author has a disability that prevents him/her from physically signing documentation. These providers must be able to provide proof to the Medicare contractor of their inability to sign their signature due to their disability. By affixing the rubber stamp, the provider is certifying that they have reviewed the document. So if your hospital has a provider that uses a rubber stamp due to a physical disability remember to include the required proof of their inability to sign when you submit medical records containing their stamped signature to a Medicare review contractor.

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

Please share this article with the therapists at your facility.

In last week’s Wednesday@One, we discussed therapy documentation in the evaluation, re-evaluation, plan of care, and certification. This week we will note some potential areas of improvement for therapy documentation in the daily treatment notes, progress notes, and the discharge summary. Like last week, we encourage providers to review the

Daily Treatment Notes

• Daily notes should list each specific intervention/modality provided to the patient for both timed and untimed codes.
• Medicare requires that the treatment notes include the total treatment time in minutes (includes both timed and non-timed codes) and the total minutes of the timed codes. Therapists need to know which treatments are timed codes and which are non-timed codes.   Non-timed codes are reported as one unit per day while the total number of units allowed for timed codes is restricted by the total timed code treatment minutes. For example if a patient receives 10 minutes of therapeutic exercise, 10 minutes of neuromuscular re-education and 10 minutes of manual therapy, the total timed code minutes equals 30 minutes which is 2 units. This patient may have also received 20 minutes of unattended electrical stimulation; this is included in the total treatment time for a total of 50 minutes, but does not affect the calculation of timed code units since it is an untimed code.
• Units of timed codes are based on the following time scale:
• 8-22 minutes = 1 unit
• 23-37 minutes = 2 units
• 38-52 minutes = 3 units
• 53-67 minutes = 4 units, etc.
• The therapy professional(s) providing the treatment must sign the treatment note and include their credentials.
• Extra documentation in the daily notes, though not required, often helps to support medical necessity in case of a Medicare audit. This may include noting the patient’s response or any assistance / instruction the patient required. If pain is part of the patient’s functional deficit, a numeric evaluation or discussion of the patient’s pain is recommended.
• Some LCDs list specific requirements for certain therapy services. For example, Cahaba’s Physical Therapy LCD notes that the medication and dosage information is required for iontophoresis and, for manual therapy, the area(s) being treated and the soft tissue/mobilization technique used should be documented. Be sure to review your Medicare contractor’s coverage policies for any additional documentation requirements.

Interval Progress Notes

• After the evaluation, this is the most important documentation in supporting the medical necessity of the therapy services provided. Based on our reviews of therapy records, most progress reports consistently contain all of the required elements.
• These notes must include objective measurements that describe the patient’s current function. Note that under the new functional limitation reporting requirements, the patient’s function will be reported as a percentage of impairment which must be documented in the patient’s record.
• Progress notes that allow easy comparison of the patient’s initial status and the status at last progress interval to the current status make auditing the record easier. The original and any revised goals need to be listed or referenced by a numbering system and the patient’s progress toward each goal noted.
• The clinician must document an assessment of the patient’s progress or lack of progress. Clearly explain if the patient is on target, ahead of schedule or not progressing as expected including reasons, adjustments to treatments / goals and recommendation for continuation of treatment. Remember this is where the therapist makes his/her case for the medical necessity of continuing treatment.

Discharge Summary

• A discharge note or summary is required for each episode of outpatient treatment.
• It covers the period from the last progress note to the date of discharge.
• In the case of an unanticipated discharge, the therapist uses the daily treatment notes and verbal reports from the treating assistants to make judgments for the summary.
• The discharge note requires the same elements as an interval progress note and is the last opportunity to justify the medical necessity of the entire treatment episode in case the record is reviewed.

When documenting therapy services, remember that you are presenting a “story” to justify that

1. the patient has a condition for which therapy should be beneficial,
2. the services require the skills of a therapist, and
3. the services are appropriate for the individual needs of this particular patient.

Please share this article with the therapists at your facility.

With all of the new Medicare requirements for rehabilitative therapy, such as functional limitation reporting, cap amounts applied to hospital outpatient services, and manual medical review of therapy services exceeding the threshold, we thought now would be a good time to address therapy documentation. These Medicare requirements can be found in the Medicare Benefits Policy Manual, chapter 15, section 220.3. Also most Medicare Administrative Contractor shave local coverage determinations for therapy services that include additionald ocumentation requirements.

The Medicare Benefits Policy manual details the minimum documentation requirements for therapy services. They also list documentation elements that are “encouraged” though technically not “required.” But this is a catch 22 –therapy documentation must be sufficient to support the medical necessity of the services provided. The manual states, “It is encouraged but not required that narratives that specifically justify the medical necessity of services beincluded in order to support approval when those services are reviewed.” So, like Medicare, we encourage providers to cover their bases with the amount and type of therapy documentation.

We are not going to re-list all of the documentation elements that Medicare recommends to support therapy services. Most therapists are well aware of the documentation requirements but we recommend providers carefully review the Medicare Benefits Policy Manual and any therapy LCDs for their jurisdiction for complete documentation information. We are going to discuss a few elements we have identified during therapy audits that we believe have potential for improvement. This week we will address documentation in the therapy evaluation, re-evaluation, plan of care and certification.

Evaluation

• Onset date – this is usually documented on the evaluation/certification form though the exact onset date is often hard to pin down. Our recommendation involves chronic conditionsa nd those conditions with an insidious onset. To support medical necessity, we recommend the evaluation answer these questions - If this condition has been going on for a while, why is therapy needed now? Has there been a recent decline in function, increase in pain or stiffness, increase in number of falls, or an exacerbation of the condition,etc.? Is the therapy intended to improve function or prevent further decline? Documentation that clearly addresses these questions helps to support the medical necessity of the therapy services.
• ADLs, ADLs, ADLs – The evaluation will include the patient’s functional deficit with objective measurements, but discussing the patient’s prior function and current limitations in terms of activities of daily living helps to support the medical necessity of the planned therapy. It is great to know the patient has limited mobility or restricted range of motion, but understanding the patient is unable to go grocery shopping or dress themselves is more dramatic and convincing of the need for treatment.

Plan of Care

• ADLs Again – In addition to the objective measures in the goals, linking the goals to improvement in a particular activity of daily living makes the goal more meaningful to the patient and to an outside reviewer.
• The functional impairments identified and expressed in the long term treatment goals must be consistent with those used in the claims-based functional reporting, using non-payable G-codes and severity modifiers.

Re-evaluation

• Continuous assessment of the patient's progress is a component of ongoing therapy services and is not payable as a re-evaluation.
• Re-evaluations are indicated when there are new clinical findings, a significant change in thepatient's condition, or failure to respond to the therapeutic interventionsoutlined in the plan of care.

Certification

• Certification requires a dated signature on the plan of care or some other document that indicates approval of the plan of care. Make sure the signature of the certifying practitioner is dated and be sure to include a copy of the signed certification when submitting records for external review. Medicare may deny services if a signed certification if not available in the medical records submitted for review.
• Let’s discuss timing of the certification -Certifications should be obtained as soon as possible after the plan of care is established or at least within 30 days of the initial treatment. Certifications are acceptable without justification for 30 days after they are due but certifications delayed beyond this time frame should include evidence to justify the delay.Evidence that the provider made immediate and on-going attempts to obtain the certification signature should be included in the record. Note however that delayed certifications are accepted by Medicare unless the contractor has reason to believe that there was no physician involved in the patient’s care, or treatment did not meet the patient’s need (and therefore, the certification was signed inappropriately).

Next week, we will look at daily treatment notes, progress notes, and the discharge summary.

 

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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Last Friday, CMS issued Transmittal R442PI which clarifies the requirements necessary for amendments, corrections and late entries to the medical record to be considered by Medicare contractors during medical review. Medicare contractors that review records for payment determinations include the Medicare Administrative Contractors (MACs), Comprehensive Error Rate Testing (CERT), Recovery Auditors (RAs or RACs) and Zone Program Integrity Contractors (ZPICs).

Providers are encouraged to enter all relevant documents and entries into the medical record at the time they are rendering the service. If actions that were actually performed were not properly documented at the time of the service, a correction, amendment or late entry is acceptable for Medicare review only if it adheres to the following standards:

• Any amendment, correction or late entry shall be clearly and permanently identified as such,
• The date and author must be clearly identified, and
• Original content must also be clearly identified and not deleted.

These requirements apply to both paper and electronic medical records.

Corrections to paper medical records require that:

• The original content is still readable which can be accomplished by using a single line strike through
• The author of the alteration sign and date the revision
• Amendments or late entries be clearly signed and dated upon entry into the medical record.

Acceptable revisions in an electronic record must:

• Distinctly identify any amendment, correction or delayed entry, and
• Provide a reliable means to clearly identify the original content, the modified content, and the date and authorship of each modification of the record.

The requirements note that Medicare reviewers shall exclude from consideration undated or unsigned entries handwritten in the margin of a document. The manual also warns against potentially fraudulent entries.