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July 2012 Vol. 15, No. 7 What to expect when coding CAD, MI with ICD-10-CM Let’s get to the heart of the matter. ICD-10-CM coronary artery disease (CAD) and myocardial infarction (MI) codes will undoubtedly differ from their ICD-9-CM counterparts in some ways, but some aspects will remain the same. Native and bypass grafts In ICD-9-CM, CAD appears in category 414. ICD-10 code I25.- denotes CAD. Both ICD-9-CM and ICD-10CM codes indicate whether CAD is in the native artery or a bypass graft. The term “native artery” describes an artery with which a patient is born and that has not been grafted during a coronary artery bypass graft (CABG) procedure. A “bypass graft” is a graft inserted by a surgeon during a CABG procedure to bypass a blocked coronary artery. ICD-10-CM code category I25.1 denotes CAD of a native artery. Patients can also have CAD of several types of bypass grafts, including: ➤➤ Unspecified (I25.700–I25.709) ➤➤ Autologous vein (i.e., a vein that originates from the patient, such as the saphenous This month’s tip: Learn vein graft in the what inpatient coders, who leg that is used to don’t typically assign E/M create a bypass codes, should know about in the coronary documentation of history of artery) (I25.710– present illness on p. 12. I25.719) ➤➤ Autologous artery (i.e., an artery that originates from the patient, such as an internal mammary artery graft that is used to create a bypass in the coronary artery) (I25.720–I25.729) ➤➤ Non-autologous biological (i.e., the grafting material doesn’t originate from the patient) IN THIS ISSUE (I25.730–I25.739) p. 5 Recovery Auditors Learn how the three-day rule has changed and how this affects hospitals as Recovery Audits get under way. Patients can also have CAD in a transplanted heart. In this scenario, coders should report I25.75- for CAD of the native artery and I25.76- for CAD of a bypass graft. p. 6 Three-day rule Learn important details about the three-day rule that every inpatient coder should know. p. 8 Malnutrition New clinical guidelines for malnutrition, which has never had universally accepted clinical criteria, could help alleviate compliance challenges associated with coding the condition. p. 10 Clinically Speaking Robert S. Gold, MD, ponders the causes of mechanical and paralytic ileuses. p. 12 E/M documentation Inpatient coders don’t typically assign E/M codes, but they should be aware of documentation of the history of present illness. Inside: Coding Q&A Documenting the specific type of bypass graft is important because it affects code assignment, says Shannon E. McCall, RHIA, CCS, CCS-P, CPC, CPC-I, CEMC, CCDS, director of HIM and coding at HCPro, Inc., in Danvers, Mass. Most physicians tend to only document “patient had a CABG or history of CABG”—and not the specific graft that was used. CAD and angina pectoris If a patient has both CAD and angina, coders using ICD-9-CM must assign a code for each condition separately. They report a code from category 414.0x for CAD Briefings on Coding Compliance Strategies Page 2 and either code 411.1 (unstable angina) or code 413.9 July 2012 However, when both conditions are POA and both are (other and unspecified angina pectoris) for angina. How- treated equally during a hospital stay, coders often have ever, this has always raised a question about sequencing, difficulty determining which should be reported as the particularly because code assignment order affects MS- principal diagnosis, says McCall. DRG assignment. The good news is that coders using ICD-10-CM won’t “What usually prompts the person to come in the need to worry about sequencing these two conditions facility is the angina. Angina is basically a thoracic chest because CAD codes are combination codes. They include pain when the heart muscle doesn’t get enough blood,” additional characters that denote the presence or absence says McCall. “So the question is, although the angina of angina pectoris. For example, ICD-10-CM code is what brought them in, what’s the underlying cause I25.110 denotes CAD of the native artery with unstable of the angina? In many cases, it’s the underlying CAD. angina. ICD-10-CM code I25.721 denotes CAD of auto The person wouldn’t have likely had the angina if they logous artery coronary artery bypass graft(s) with angina didn’t have CAD.” pectoris with documented spasm. ICD-10-CM code Generally, CAD is the principal diagnosis even when diagnostic tests confirming the condition are performed before admission, she says. I25.751 denotes CAD of native artery of transplanted heart with angina pectoris with documented spasm. Similarly, ICD-10-CM code I25.10 denotes CAD of native artery without angina pectoris. ICD-10-CM code Editorial Advisory Board Briefings on Coding Compliance Strategies Associate Editorial Director: Ilene MacDonald, CPC Managing Editor: Geri Spanek Contributing Editor: Lisa Eramo, [email protected] I25.81- denotes CAD of other coronary vessels without angina pectoris. Coders using ICD-10-CM must remember that they may not assign unstable angina separately when a patient also has CAD, says McCall. “Coders are so used to assigning separate codes for CAD and angina, so we have to be Paul Belton, RHIA, MHA, MBA, JD, LLM Vice President Corporate Compliance Sharp HealthCare San Diego, Calif. Laura Legg, RHIT, CCS Revenue Control Coding Consultant Revenue Cycle Management Washington/Montana Regional Services Providence Health & Services Renton, Wash. very careful because technically if you look up the main Gloryanne Bryant, RHIA, CCS, CDIP, CCDS HIM Consultant Fremont, Calif. Monica Lenahan, CCS Manager of Coding Education and Compliance Revenue Management Centura Health Englewood, Colo. entry stating ‘angina, with atherosclerotic heart disease,’ Shannon E. McCall, RHIA, CCS, CCS-P, CPC, CPC-I, CEMC, CCDS Director of Coding and HIM HCPro, Inc. Danvers, Mass. Although patients can have unstable angina without William E. Haik, MD, FCCP, CDIP Director DRG Review, Inc. Fort Walton Beach, Fla. James S. Kennedy, MD, CCS Managing Director FTI Healthcare Atlanta, Ga. Jean Stone, RHIT, CCS Coding Manager - HIMS Lucile Packard Children’s Hospital at Stanford Palo Alto, Calif. term angina, unstable in the Alphabetic Index … it gives you one option: I20.0—that is, unless you notice the which provides a cross-reference to the CAD entry in the index. If you go to I20.0, it says unstable angina.” CAD, this is not a common occurrence, she says. Coders should note that an Excludes1 note in ICD10-CM category I20 precludes coders from assigning this code with a code from the I25.1- or I25.7- categories or with code I23.7 (postinfarction angina), says McCall. Code category I20 is reserved for patients with angina Briefings on Coding Compliance Strategies (ISSN: 1098-0571 [print]; 1937-7371 [online]) is published monthly by HCPro, Inc., 75 Sylvan St., Suite A-101, Danvers, MA 01923. Subscription rate: $249/year. • Briefings on Coding Compliance Strategies, P.O. Box 3049, Peabody, MA 01961-3049. • Copyright © 2012 HCPro, Inc. All rights reserved. Printed in the USA. Except where specifically encouraged, no part of this publication may be reproduced, in any form or by any means, without prior written consent of HCPro, Inc., or the Copyright Clearance Center at 978-750-8400. Please notify us immediately if you have received an unauthorized copy. • For editorial comments or questions, call 781-639-1872 or fax 781-639-7857. For renewal or subscription information, call customer service at 800-650-6787, fax 800-639-8511, or email [email protected]. • Visit our website at www.hcpro.com. • Occasionally, we make our subscriber list available to selected companies/vendors. If you do not wish to be included on this mailing list, please write to the marketing department at the address above. • Opinions expressed are not necessarily those of BCCS. Mention of products and services does not constitute endorsement. Advice given is general, and readers should consult professional counsel for specific legal, ethical, or clinical questions. © 2012 HCPro, Inc. not related to CAD. Coders can—and should—make assumptions about causal relationships between CAD and angina when both are documented, says McCall. This liberty doesn’t often occur in the coding world. However, the ICD-10-CM For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at www.copyright.com or 978-750-8400. Briefings on Coding Compliance Strategies July 2012 Page 3 Official Guidelines for Coding and Reporting, Chapter 9 Consider the following scenario. A patient has (Diseases of the Circulatory System), subsection b CAD without angina pectoris. The patient previously (Atherosclerotic CAD and angina) state: underwent a CABG procedure. The physician didn’t A causal relationship can be assumed in a patient with document whether CAD is in the bypass graft or the na- both atherosclerosis and angina pectoris, unless the documenta- tive vessel. When documentation is unclear, coders using tion indicates the angina is due to something other than the ICD-10-CM should default to I25.10, which is a non-CC atherosclerosis. condition. If a physician had clarified that the patient had CAD of a bypass graft without angina pectoris, cod- “If the documentation states that the patient has both ers could report I25.810 (atherosclerosis of CABG with- CAD and angina pectoris, the combination code can be out angina pectoris) or I25.812 (atherosclerosis of bypass used,” says Melanie Endicott, MBA/HCM, RHIA, graft of coronary artery of transplanted heart without CCS, CCS-P, director of professional practice at AHIMA angina pectoris) if the patient had a transplanted heart. in Chicago. “Since the combination code for CAD and Both of these ICD-10-CM codes are CC conditions. angina doesn’t exist in ICD-9-CM, it may take some time for coders to remember the rule to combine these two conditions when coding in ICD-10-CM.” MIs and anatomical specificity MIs appear in ICD-10-CM code categories 410.x (acute MI), 414.8 (chronic MI), and 412 (old MI). ICD-10-CM MI Default code changes Coding Clinic, Fourth Quarter 2004, instructs coders codes include I21.- (ST elevation MIs and non-ST elevation MIs [STEMI and NSTEMI, respectively]), I22.- (subsequent using ICD-9-CM to default to code 414.01 (CAD of a STEMI and NSTEMI), I25.2 (old MI), and I25.9 (chronic native artery) for patients with CAD who have never MI). A STEMI is due to a sudden occlusion of a coronary undergone a CABG procedure, says McCall. Coding artery, says McCall. The usual treatment is thrombolytic Clinic, Fourth Quarter 2004, instructs coders to default therapy. An NSTEMI is generally due to unstable plaque to 414.00 (CAD of unspecified artery) for patients with with an accumulation of platelets and is treated with anti- CAD who have undergone a CABG when documenta- coagulants and platelet inhibitors, she says. tion doesn’t indicate whether the CAD is in the native artery or the bypass graft. “This has always raised an eyebrow because techni Code I21.- denotes the specific wall and specific coronary artery involved in an MI. Although ICD-9CM denotes the specific wall (i.e., the fourth digit), the cally, when you perform a bypass graft, you don’t get specificity in ICD-10-CM regarding the coronary artery rid of the atherosclerosis that’s in the native artery,” is new. For example, ICD-10-CM code I21.01 denotes says McCall. “So it seemed kind of odd that Coding Clinic left main coronary artery, and code I21.02 denotes left would say if you’ve got a bypass graft and CAD, you anterior descending coronary artery. have to use the unspecified vessel even though you This information helps capture exactly where an know the patient still has CAD in their native artery. infarction is occurring, says McCall. Coders typically find That’s why the physician performed the bypass initially.” this information in cardiac catheterization reports. ICD-10-CM remedies this; the Alphabetic Index maps Coders should review current MI documentation to CAD, not otherwise specified, to the default code for determine whether it specifies both the wall and specific CAD of the native artery (I25.10), says McCall. coronary artery, says Endicott. “If all necessary documen- However, clarifying whether CAD is of the native artery tation is not present, then this is an opportunity to work or a bypass graft is important because this information can together with the cardiac physicians to share with them have financial ramifications in ICD-10-CM, she says. what documentation is required with the new codes.” © 2012 HCPro, Inc. For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at www.copyright.com or 978-750-8400. Briefings on Coding Compliance Strategies Page 4 Note that ICD-10-CM guidelines provide additional July 2012 they have a fifth digit of 1 (initial episode of care), says information about the evolution of an NSTEMI to a McCall. In ICD-10-CM, the MS-DRG remains the same STEMI. The ICD-10-CM Official Guidelines for Coding and regardless of whether a patient is being treated for a first Reporting, Chapter 9 (Diseases of the circulatory system), MI or a subsequent one, she says. Codes I21.- and I22.- subsection e (Acute MI) state: are considered MCCs and will map to the same DRG If NSTEMI evolves to STEMI, assign the STEMI code. If STEMI converts to NSTEMI due to thrombolytic therapy, it is still coded as STEMI. when reported as the principal diagnosis. Remember that coders may need to clarify documentation that doesn’t specify the date of the first MI, says McCall. This date is important because it determines Acute and subsequent MIs Among the most noticeable differences between ICD9-CM and ICD-10-CM is that the latter defines an acute MI as one in which the patient’s symptoms last for fewer whether the subsequent MI is truly subsequent to the first MI or whether it is considered a new MI, which should be reported with I21.-, she says. Sequencing acute and subsequent MIs will depend than four weeks, says McCall. This differs from ICD-9- on the circumstances of an admission, says McCall. For CM, which classifies an acute MI as one with a stated example, a patient suffered a STEMI involving the left duration of eight weeks or fewer. circumflex coronary artery two weeks earlier and is dis- If patients have a second, subsequent MI during the charged. The same patient is admitted today for a STEMI of acute phase (i.e., during the four-week period after the the anterior wall. Coders should assign I22.0 (subsequent first MI), coders must assign a code for the subsequent STEMI of anterior wall) followed by I21.21 (STEMI left MI (I22.-) as well as a code for the first MI (I21.-), says circumflex). Report I22.0 as the principal diagnosis because Endicott. The ICD-10-CM Official Guidelines for Coding and the subsequent MI (i.e., the one that occurred within four Reporting, Chapter 9 (Diseases of the Circulatory System), weeks of the initial MI) is the reason for the admission. subsection e(4) (Subsequent acute MI) reiterate this. Also consider this example. A patient is admitted for Before assigning a code from category I22, coders an acute MI and suffers a subsequent MI two days later must confirm that the patient suffered two MIs within while still hospitalized. Coders should report a code from four weeks, says McCall. ICD-10-CM specifies that a the I21.- category as the principal diagnosis and a code subsequent MI is one that occurs within four weeks from the I22 category as secondary. (28 days) of a previous MI, regardless of site. “It’s very different from ICD-9. In ICD-10, it’s really Old MI showing the true picture,” says McCall. “When patients Coders should report I25.2 for an old MI (i.e., a personal have MIs, it’s not uncommon for them to have another history of MI), says Endicott. This code would apply to any one a short time after having the first one. In ICD-9, we MI that occurred more than four weeks before admission. don’t have a way to address this. We may end up coding it As in ICD-9-CM, this code remains in the disease-specific as two separate episodes of care—initial and subsequent.” chapter rather that with other codes that denote personal Coders are not familiar with assignment of a separate code for a subsequent MI, says McCall. In ICD-9-CM, the history (i.e., ICD-10-CM Z codes), says McCall. Coders must exercise caution when documentation term “subsequent” refers to a subsequent episode of care states “history of MI,” particularly if it doesn’t specify and is included as a part of the fifth digit for the MI code. when the MI occurred, says McCall. “Technically, coders In ICD-10-CM, it refers to a second MI rather than an should be coding that with I22 and I21, but I could see episode of care. how someone could [incorrectly assign] that and code ICD-9-CM MI codes are considered MCCs only if © 2012 HCPro, Inc. I21 and I25.2 instead,” she says. n For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at www.copyright.com or 978-750-8400. Briefings on Coding Compliance Strategies July 2012 Page 5 Recovery Auditors focus on three-day rule The inevitable audits of the three-day payment rule have begun. match between the ICD-9-CM diagnosis codes for the outpatient service and the inpatient admission. Connolly, Inc., the Recovery Auditor for Region C, “Often, we would have no exact match between the announced it would use automated reviews to begin symptom code that would be used on the outpatient auditing to assess compliance with the rule that con- basis and the final diagnosis code that would be used on tinues to challenge providers. CMS approved the issue the inpatient basis,” says Hoy. “The old rule was purely effective March 20. based on the relationship of the codes. It was not based Specifically, Connolly is auditing outpatient hospital claims based on whether the associated inpatient discharge occurred before or after June 25, 2010. on any clinical relationship.” For example, a patient presents to the ED with a broken toe and undergoes an x-ray of the toe. The patient Why? sustains trauma as a result of a motor vehicle accident June 25 marks the enactment of section 102 of the and is admitted due to the trauma the same day. Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010. Pursuant to the old rule (i.e., before June 25, 2010), the ED visit would have been billed separately because This law includes important changes pertaining to the three-day payment rule, and hospitals should be aware of them, says Kimberly Anderwood Hoy, JD, CPC, it’s nondiagnostic and unrelated to the admission, says Hoy. However, the x-ray for the broken toe would have director of Medicare and compliance at HCPro, Inc., in been bundled into the inpatient admission because it’s Danvers, Mass. diagnostic, and all diagnostic services were bundled, regardless of whether they were related, she says. Out with the old The result would be the same if these services Before June 25, 2010, all diagnostic and related nondiagnostic services were subject to the payment rule on the date of admission and during the three calendar days before the date of admission. only on the date of admission. The old rule didn’t differentiate between the date of admission and the three days prior to admission, Hoy CMS defined related services as those having an exact BCCS Subscriber Services Coupon ❑ Start my subscription to BCCS immediately. Options No. of issues Cost ❑ Electronic 12 issues $249 (CCSE) explains. 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Title Organization Address City State Phone Fax ZIP Email address (Required for electronic subscriptions) ❑ Payment enclosed. ❑ Please bill me. ❑ Please bill my organization using PO # ❑ Charge my: ❑ AmEx ❑ MasterCard ❑ VISA ❑ Discover Signature (Required for authorization) Card # Expires (Your credit card bill will reflect a charge from HCPro, the publisher of BCCS.) Mail to: HCPro, P.O. Box 3049, Peabody, MA 01961-3049 Tel: 800-650-6787 Fax: 800-639-8511 Email: [email protected] Web: www.hcmarketplace.com © 2012 HCPro, Inc. For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at www.copyright.com or 978-750-8400. Briefings on Coding Compliance Strategies Page 6 In with the new After June 25, 2010, however, the rule changed and became somewhat more complex in the process. From this date forward, all diagnostic and nondiagnostic services—regardless of whether they are related to an admission—are subject to the rule when they occur on July 2012 (attestation of unrelated outpatient nondiagnostic services) in the following situation: ➤➤ The service is clinically distinct or independent from the reason for the inpatient admission ➤➤ Documentation in the medical record supports the belief that the service is unrelated the date of admission. Services provided during the three days before admis- In the previously described scenario, both the ED visit sion are handled differently, however. All diagnostic and the x-ray are bundled in the inpatient admission be- services provided during the three days before admission cause the new rule (i.e., effective June 25, 2010) bundles are subject to the rule and must be bundled. Nondiag- all diagnostic and nondiagnostic services provided on the nostic services provided during the three days before date of admission, says Hoy. admission are bundled only if they are clinically related to the admission. However, coders must remember the new definition of related because it determines whether a hospital will Unlike in the past, when CMS based the relation bundle into an inpatient claim any outpatient nondiag- on an exact match of ICD-9-CM diagnosis codes, CMS nostic services subject to the rule that occur during the now defines related as being clinically associated with three days before the admission, says Hoy. the reason for a patient’s inpatient admission. CMS also For example, a patient presents with shortness of presumes that preadmission services are related to the breath (786.05) and chest pain (786.50) for an office admission. Hospitals must affirmatively attest if the ser- visit at a physician practice wholly owned or operated vices are not related. by a hospital. The patient is admitted to the hospital that CMS has instructed hospitals to bill unrelated nondiagnostic services to Part B with condition code 51 owns the physician practice the next day and is diagnosed with myocardial infarction (410.xx). Three-day rule Important facts every inpatient coder should know The three-day payment rule, which defines certain pread- same day as a prior admission, hospitals should combine the mission services as inpatient operating costs, has implications admissions or report condition code B4 if the readmission is for inpatient coders. unrelated to the prior one. Inpatient coders should remember the following details pertaining to this rule: ➤ Inpatient-only services provided on an outpatient basis during the three-day window are ex- ➤ Outpatient services subject to the window cluded from the rule. “When there is an inpatient-only are paid as part of the inpatient DRG. These servic- procedure prior to an inpatient order, CMS has said it con- es are billed on the inpatient claim to report costs, explains siders the procedure non-covered when it was rendered,” Kimberly Anderwood Hoy, JD, CPC, director of Medicare says Hoy. “Because it was noncovered when it was rendered, and compliance at HCPro, Inc., in Danvers, Mass. it cannot be moved over and turned into a covered service ➤ Part A (inpatient) services are excluded from the rule. This is true even when Part A services are per- under the three-day payment window.” Hospitals should bill the inpatient-only procedure on a formed within the three-day window at the same hospital, TOB 110 (inpatient non-covered) solely for internal processing says Hoy. If a patient is readmitted to the hospital on the purposes at CMS, says Hoy. © 2012 HCPro, Inc. For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at www.copyright.com or 978-750-8400. Briefings on Coding Compliance Strategies July 2012 Page 7 Under the old rule, hospitals would have billed ➤➤ Diagnostic revenue codes are never billed on an out- the office visit separately from the admission because patient claim up to three days before an inpatient the ICD-9-CM diagnosis codes didn’t match exactly admission (i.e., the services weren’t related). Under the new rule, hospitals should bundle the outpatient services into Hospitals should beware of the audit item related to the inpatient claim because they are clinically related, services billed before June 25, 2010, because Connolly’s says Hoy. description of the issue may be erroneous, says Hoy. The audit appears to include all nondiagnostic revenue codes. Beware of Recovery Auditors Acknowledging the importance of this change, Connolly will audit to ensure the following: Before June 25, 2010 ➤➤ Certain outpatient diagnostic revenue codes and non- However, bundling depends on the ICD-9-CM codes for each case. Nondiagnostic revenue codes can and should be separately billed before admission if diagnosis codes for the service and the inpatient admission don’t match, she says. n diagnostic revenue codes are not billed within three days of an inpatient admission Editor’s note: The information in this article was originally presented during HCPro’s audio conference “Mastering the June 25, 2010, and thereafter ➤➤ No outpatient claim exists on the date of inpatient admission, regardless of diagnosis codes or revenue codes Three-Day Payment Window.” To learn more or to purchase an on-demand version of this audio conference, visit www. hcmarketplace.com/prod-10185. For more information about compliance with the ➤➤ All nondiagnostic outpatient charges subject to the three-day payment rule, download HCPro’s white paper rule are not billed separately unless they are accom- at http://blogs.hcpro.com/revenuecycleinstitute/ panied by condition code 51 wp-content/uploads/2012/04/2012-Three-day-rule.pdf. ➤ Conditions related to services subject to the An ICD-9-CM procedure code added to the inpatient claim three-day payment window are considered POA. that is surgical in nature could also change the DRG from Coders should code diagnoses for bundled services as POA medical to surgical. DRGs frequently shift when patients when they are present at the time of the admission order are admitted within three days of outpatient surgery due even if they are not present at the time of outpatient regis- to complications of the surgery. When converted to ICD-9- tration, says Hoy. Refer to CMS’ August 9, 2012, Joint Signa- CM codes, the claim includes inpatient surgical codes that ture Memo for more information. commonly shift the DRG from a medical DRG for the com- ➤ Abiding by the three-day payment rule can shift a DRG. CMS has instructed providers to include plications, she says. ➤ Not all CPT codes have a corresponding ICD- charges for all services identified as subject to the payment 9-CM Volume 3 code. “There’s a very small number of window on the Part A inpatient claim for the admission, ICD-9 Volume 3 codes compared to CPT. That will not be says Hoy. This includes all charges, revenue codes, and true when it comes to ICD-10,” says Hoy. Most CPT codes ICD-9-CM diagnosis and procedure codes. This requires will have an ICD-10-PCS equivalent, she says. “It will be that coders convert CPT codes to ICD-9-CM codes when interesting to see what the direction will be in terms of con- possible, she says. An ICD-9-CM code added to an inpa- verting if we’ll only have to convert those codes that affect tient claim that is a CC or MCC could increase the DRG. the DRG.” ® © 2012 HCPro, Inc. For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at www.copyright.com or 978-750-8400. Briefings on Coding Compliance Strategies Page 8 July 2012 Malnutrition New criteria could help ensure consistent coding New clinical guidelines for malnutrition could help alleviate compliance challenges associated with coding codes will better reflect the clinical presentations that providers encounter when assessing malnutrition, she says. the condition, which has never had universally accepted Don’t fall into a compliance trap clinical criteria. New guidelines published in the May 2012 Journal This all comes as good news for coders and providers of the Academy of Nutrition and Dietetics, represent a con- who continue to struggle with third-party audits of sensus statement of the American Academy of Nutrition CC and MCC conditions, including malnutrition, says and Dietetics (the Academy) and the American Society James S. Kennedy, MD, CCS, CDIP, managing for Parental and Enteral Nutrition (ASPEN). The Acad- director at FTI Consulting in Atlanta. emy and ASPEN both advocate for provider use of a One need not look far to discover the case involving standardized set of diagnostic characteristics to identify a Maryland hospital whose employees allegedly used and document adult malnutrition, says Jane White, leading queries to add malnutrition as a secondary diag- professor emeritus in the department of family medi- nosis. Good Samaritan Hospital in Baltimore denied the cine at the University of Tennessee in Knoxville. White accusations, but agreed to pay nearly $800,000 to resolve also serves as chair of the Academy’s adult malnutrition the False Claims Act violation allegations, according to work group. The Academy and ASPEN say malnutrition a March 28 press release from the U.S. Department of should be diagnosed when at least two or more of the Justice, available at http://tinyurl.com/d4j6hqy. following six characteristics are identified: “If patients had truly had malnutrition, it wouldn’t ➤➤ Insufficient energy intake have been as much of an issue,” says Kennedy. He attri- ➤➤ Weight loss butes incorrect malnutrition coding to a lack of consis- ➤➤ Loss of muscle mass tent clinical criteria and says that many CDI programs ➤➤ Loss of subcutaneous fat also incorrectly define malnutrition solely on low albu- ➤➤ Localized or generalized fluid accumulation that may min or prealbumin levels. sometimes mask weight loss ➤➤ Diminished functional status as measured by hand grip strength Another case involved Shasta Regional Medical Center in Redding, Calif., which allegedly billed Medicare for treatment of more than 1,000 cases of kwashiorkor over a two-year period, according Providers must assess these six characteristics in the to a California Watch analysis of state health data. context of an acute illness or injury, a chronic illness, or California Watch describes itself as “the largest group social or environmental circumstances to determine if of journalists dedicated to investigative reporting in the malnutrition is present and whether it’s severe or non- state” on its website. severe (moderate). The article, available at http://tinyurl. Kwashiorkor, a form of malnutrition that occurs com/ckbclxa, provides a table with more detailed clinical when a diet lacks sufficient protein, is very rare in the criteria to which providers can refer when documenting United States, and is not something that coders encoun- severity levels for malnutrition. ter frequently, says Alice Zentner, RHIA, director of The Academy and ASPEN have asked the NCHS to auditing and education at TrustHCS in Springfield, Mo. adopt ICD-9-CM malnutrition codes that use etiological- Physicians must specifically document the term “kwashior- based nomenclature, says White. If adopted, the ICD-9-CM kor” for coders to report it, she says. © 2012 HCPro, Inc. For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at www.copyright.com or 978-750-8400. Briefings on Coding Compliance Strategies July 2012 Although the ICD-9-CM index instructs coders to Page 9 labs or clinical findings,” he says. Consider the following report code 260 (kwashiorkor) for unspecified protein query based on the new criteria from the Academy malnutrition, Coding Clinic, Third Quarter 2009, p. 6 and ASPEN: discourages assignment of this code when physicians The following clinical indicators are in the medical record: document moderate or mild protein malnutrition, says ➤➤ Current BMI _____ Kennedy. ➤➤ Stress indicator – Acute illness – Chronic illness – Social ➤➤ Energy intake over the previous ___ days ___% Rely on helpful strategies Coders should remember and use the following strategies: ➤➤ Amount of weight loss over ___ days ____% ➤➤ Loss of subcutaneous fat (circled) –– None – Mild – Moderate – Severe ➤➤ Don’t always assume documentation is correct. It may seem counterintuitive, but coders should question a diagnosis when it appears that no clinical evidence supports it, says Kennedy. For example, physicians often incorrectly diagnose malnutrition based solely on a low ➤➤ Loss of muscle mass (circled) –– None – Mild – Moderate – Severe ➤➤ Fluid accumulation (circled) –– None – Mild – Moderate – Severe ➤➤ Measurably reduced grip strength present – Yes – No albumin or prealbumin, he says. Third-party auditors will challenge this diagnosis, and coders should also question it, he says. Please indicate what diagnosis best correlates with these findings: Coders must ensure that severe protein-calorie ➤➤ Cachexia without malnutrition malnutrition—an MCC—is documented consistently ➤➤ Nutritional risk without malnutrition and treated, says Zentner. “If that code is on a record, it’s ➤➤ Malnutrition, severity unknown certainly a red flag for a RAC to audit,” she says. ➤➤ Malnutrition, non-severe (moderate) Malnutrition must also meet the definition of a ➤➤ Malnutrition, severe, not otherwise specified reportable secondary diagnosis, says Zentner. Coders ➤➤ Marasmus – A specified severe protein-calorie malnutrition should also remember not to report cachexia, a wasting ➤➤ Kwashiorkor – A specified severe protein malnutrition syndrome, as malnutrition—instead, cachexia is denoted ➤➤ Another medical diagnosis by a symptom code (799.4), she says. ➤➤ Other (please specify) Hospitals should develop policies that explain how ➤➤ Cannot be determined coders should address inconsistent and unreliable diagnoses, says Kennedy. Unreliable diagnoses are those that Other clinical evidence in the record that might sug- don’t meet reasonable criteria established by the medical gest malnutrition includes chronic disease, insufficient staff. Once identified, these diagnoses should be vetted intake pre- or postoperatively, infection, malabsorption, by a coding supervisor, physician advisor, or CDI special- muscle wasting, poor wound healing, or lethargy, says ist, he says. Zentner. ➤➤ Beware of leading queries. A malnutrition ➤➤ Work with CDI specialists. Ask CDI special- diagnosis often may not be documented when a patient ists to educate physicians about malnutrition clinical does, indeed, have the condition. However, as the Good indicators, advises Kennedy. Also advocate for pre- Samaritan Hospital case demonstrates, coders must be discharge queries. “The query for malnutrition is really certain that they don’t lead physicians when requesting best done in a pre-discharge environment in collabo- clarification, says Kennedy. “We are allowed, as coders, ration with dietitians, nutritional teams, and the CDI to ask providers for the clinical significance of abnormal team,” he says. n © 2012 HCPro, Inc. For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at www.copyright.com or 978-750-8400. Briefings on Coding Compliance Strategies Page 10 July 2012 Pondering causes of mechanical, paralytic ileuses by Robert S. Gold, MD Let me explain the digestion process. People intake foods, solids, and liquids that occasionally mix with gases. The contents traverse the esophagus and enter the stomach where they encounter acid. The stomach churns the food and liquid with acid and peptic juices and prepares it for the duodenum. There, bile juices and pancreatic chemicals emulsify the fat. They also break down proteins into amino acids and complex sugars into simple sugars for subsequent absorption in the jejunum and ileum. The residue moves through a 24-foot tunnel before it arrives in the large intestine where bacteria breaks it down and dries it out by absorption. Finally, the body excretes the waste. This entire process of transit is called peristalsis. During normal peristalsis, the intestinal wall muscles narrow and lengthen periodically. However, the intestinal tract may suffer from many diseases that can interrupt this process. This column addresses the topic of ileus, which is derived from the Greek term for “twisted.” An ileus caused by a length of bowel that is twisted on its mesentery can cause twisting of the veins that drain the length of bowel as well as the arteries that supply that bowel. The length of bowel supplied by that artery and vein can die, and the twisting causes an obstruction that stops the progression of food through the gastrointestinal tract. Mechanical ileus A mechanical ileus (i.e., mechanical obstruction) occurs when a physical blockage impedes flow. A nickel swallowed by a patient could become stuck in a portion malignant neoplasm that grows large enough, can also block intestinal flow. Herniation of a length of intestine through a defect in the abdominal wall (e.g., umbilical hernia, inguinal hernia, or paraesophageal hiatal hernia) also can block intestinal flow. Herniation through a defect in the fastening of the mesentery inside the abdomen (e.g., paraduodenal fossa hernia or Ladd’s bands) can also lead to intestinal blockage. Blockage can occur when a length of intestine becomes twisted. This occurs with volvulus of the sigmoid, volvulus of the cecum, and adhesions between loops of intestine. Intussusception, which occurs when one portion of the bowel slides into the next, can also cause obstruction. Cystic fibrosis may lead to mechanical obstruction with excessively thick meconium in the bowel of the newborn. Intestinal content above the area of blockage continues to become backed up to the point at which the patient begins vomiting. The vomitus is usually foul smelling in nature. Mechanical ileuses are treated surgically, which usually leads to a total resolution of the problem. This is true even if a portion of the bowel has become gangrenous. Coders should identify each cause of intestinal obstruction with the most precise code possible. Occasionally, physicians identify a partial small bowel obstruction due to adhesions from prior surgery. Many of these cases resolve spontaneously with bowel rest. If they don’t resolve, physicians must explore the bowel and cut or cauterize adhesions to restore normal anatomy. Paralytic ileus of the intestinal tract that is smaller in diameter than the A paralytic ileus occurs when a lack of synchronized coin (e.g., the pylorus, a passage from the stomach to the peristalsis occurs in the absence of a physical blockage. duodenum, or the ileocecal valve). Viral or bacterial infections in the gastrointestinal tract A foreign body of sufficient size can cause a mechanical obstruction. A tumor, whether a benign polyp or © 2012 HCPro, Inc. usually lead to hypermotility, which often results in diarrhea. However, infection in the abdominal cavity around For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at www.copyright.com or 978-750-8400. Briefings on Coding Compliance Strategies July 2012 Page 11 the intestines can also lead to cessation of neuromuscu- However, if the surgery led to further problems with lar coordinated activity and no movement of intestinal the intestines (e.g., anastomotic leak or spillage and con- content. For example, paralysis can occur when patients tamination of the peritoneal cavity that didn’t exist prior undergoing peritoneal dialysis have infected ascites. to surgery), then a prolonged ileus could be a complica- It can also occur in patients with pelvic or abdominal tion of the operation itself. abscesses from a perforated bowel. Those with pelvic Not every ileus warrants assignment of a code. For inflammatory disease or benign spontaneous peritonitis example, an ileus that doesn’t prolong a patient’s hospi- can experience the same problem. tal stay beyond the average length of stay isn’t codeable, If an area of the intestine loses some of its blood sup- even when documented as a postoperative ileus. This ply or venous drainage due to atherosclerosis or portal reflects the physiologic ileus that follows every abdomi- venous hypertension, peristaltic activity in that area of nal surgery and is part of the recovery. It’s not codeable. the bowel may cease. Irritation of the outer peritoneal However, if the postoperative ileus causes vomit- lining of the intestine due to any cause often results in ing, or the patient required insertion of a nasogastric paralysis of that segment of bowel. This can happen in tube, coders may be able to report it. Coders can also patients with pancreatitis when digestive enzymes are assign a code for an ileus that is prolonged due to a released into the abdomen. It can also occur in conjunc- disease or due to surgery for the condition that caused tion with abdominal surgery. Each of these scenarios the ileus. However, this code should not be a compli- causes cessation of intestinal motility in the area of neu- cation code because the ileus is not a complication of romuscular function disturbance, and the entire bowel the surgery. If the late resumption in bowel activity is due to swells in size. Some localized paralyses may occur. For example, overuse of pain medication, report a code for the ileus as this can occur in newborns with Hirschsprung’s disease well as an E code for the adverse effect of the opiates or (in which parts of the nervous system in the wall of the whatever pain medication led to the ileus. large intestine are missing). It may also occur in bedbound patients with chronic constipation that can lead to Ogilvie syndrome (pseudo obstruction). Coders must always look for the cause of a paralytic Finally, if the prolonged ileus occurs due to a complication of surgery (e.g., a leak), assign a complication code. When the physician cannot determine the cause of the ileus, also consider a complication code if the patient ileus prior to coding. A physiologic paralytic ileus can starts vomiting, has had a nasogastric tube inserted, or occur after abdominal surgery when a patient has can’t resume eating for five or more days after surgery no other bowel-related problems. Patients receive no when all other causes for these symptoms have been sustenance by mouth until bowel sounds are heard or ruled out. n the patient passes flatus. However, when an abnormal process in the abdomi- Editor’s note: Dr. Gold is CEO of DCBA, Inc., a consulting nal cavity leads to surgery (e.g., appendicitis, diverticu- firm in Atlanta that provides physician-to-physician CDI pro- litis, or cholecystitis), the patient invariably had an ileus grams. Contact him at 770-216-9691 or [email protected]. going into surgery. Thus, the patient would naturally have one after the surgery as well. Depending on the severity of the inflammatory response, it could conceivably take as long as one week for the bowel to resume function. When this occurs, the ileus is caused by the disease—not by the surgery. © 2012 HCPro, Inc. Questions? Comments? Ideas? Contact Contributing Editor Lisa Eramo Telephone 401-780-6789 Email [email protected] For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at www.copyright.com or 978-750-8400. Briefings on Coding Compliance Strategies Page 12 July 2012 Emphasize importance of history of present illness Inpatient coders don’t typically assign E/M codes, but historical inventory of a patient. Historical inventory is a they should be aware of documentation of the history of patient’s account of the presenting problem obtained via present illness (HPI). the physician-patient interview process. Physicians often Why? The same documentation that affects the E/M include an extensive discussion of past history but fail to level generally also potentially affects clinical valida- provide sufficient emphasis on the current situation. This tion of ICD-9-CM code assignment, says Glenn Krauss, detracts from the more relevant reporting of a patient’s BBA, RHIA, CCS, CCS-P, CPUR, C-CDI, CCDS, an in- presenting severity of illness, signs, and symptoms, and dependent HIM consultant in Madison, Wis. The HPI, in the physician effort required to help the patient. particular, helps justify a patient’s acuity and reason for admission to the hospital, he explains. The HPI should provide a clear and concise description of the nature of the presenting problem. A deficient The HPI should always include a detailed descrip- HPI frequently leads to an E/M assignment that denotes tion of the nature of a patient’s presenting problem and a lower level than that which was provided. The physi- any of the eight elements of the HPI, including location, cian simply failed to adequately demonstrate the current quality, severity, duration, timing, context, modifying acuity of the patient and the different body areas/organ factors, and associated signs and symptoms, says Krauss. systems potentially affected by the current complaint. Without this information, hospitals will inevitably face Failure to provide an adequate, clinically relevant, and denials from third-party auditors who typically review appropriate HPI can affect coding for subsequent hospital the ED note, history and physical, and discharge summa- visits. Initial hospitalization E/M code sets require that ry—and not the entire record—when auditing, he says. documentation meets all three E/M components— “RAC contractors are making up their minds before they history, physical, and medical decision-making. Subse- even go any further. They have a tendency to prejudge the quent hospitalization codes require only two of these case based on what they read right away,” he says. three components. An HPI that is insufficient to the extent that documentation doesn’t support even the Emphasize the importance of the HPI CDI specialists and coders who discuss the importance of the HPI with physicians should address its true meaning. Ensure physicians understand that the HPI repre- lowest-level history component precludes using history as one of the two key components required for E/M assignment under subsequent hospitalization code sets. Failure to provide an adequate HPI as part of history sents present illness with an emphasis on the severity calls into question the medical necessity for ordering of signs and symptoms obtained from an interview and related diagnostic testing and therapeutic interventions and the medical necessity for the physician service. Lack Upcoming event July 10—Observation Services 2012: Build an Audit Defense, Obtain Appropriate Reimbursement, featuring Deborah K. Hale, CCS, CCDS, president of Administra- of an adequate HPI limits the usefulness of the record. Coders must remember that physician E/M services are subject to medical necessity provisions similar to all other Medicare beneficiary services ordered and provided. n tive Consultant Service, LLC, in Shawnee, Okla. To register or for more information, call 800-650-6787 or visit www.hcmarketplace.com and mention source code NEWSAD. © 2012 HCPro, Inc. Editor’s note: This article was adapted from The Documentation Improvement Guide to Physician E/M, published by HCPro, Inc., and authored by Krauss. For more information, visit http://tinyurl.com/crjq6by. For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at www.copyright.com or 978-750-8400. July 2012 A monthly service of Briefings on Coding Compliance Strategies We want your coding and compliance questions! The mission of Coding Q&A is to help you find answers to your urgent coding/compliance questions. To submit your questions, contact Briefings on Coding Compliance Strategies Contributing Editor Lisa Eramo at [email protected]. Editor’s note: Answers to the following questions are Others have described scenarios similar to the one based on limited information submitted to Briefings on posed in your question (e.g., a payer deems a single CC Coding Compliance Strategies. Review all documenta- or MCC not supported clinically despite clear documen- tion specific to your scenario before determining appropriate tation in the medical record). This can be frustrating for code assignment. hospitals. Payers that do this negate the MS-DRG logic that a patient only needs one diagnosis designated as a Recently, reviewers have denied diagnostic code 584.9 (acute renal failure [ARF]) based on laboratory CC/MCC for assignment to that MS-DRG. Exploring cases that involve patients with single CCs or values. The diagnosis is well documented and treated by MCCs makes financial sense for payers because it affects the attending physician, but reviewers say the overall reimbursement. As such, documentation and clini- laboratory values do not support the diagnosis of ARF. cal indicators in the medical record should clearly support The laboratory values (creatinine/BUN) progressed the reported diagnoses to justify code assignment. I do from normal to abnormal, and we found no defini- not know whether your organization has a documentation tive standards for laboratory parameters to meet the improvement program, but I see an opportunity for poten- definition of ARF. tial documentation improvement efforts to assist in these In accordance with coding guidelines for reporting secondary diagnoses, ARF was clinically evaluated, situations. RIFLE criteria are helpful with respect to understand- the patient underwent therapeutic and diagnostic ing clinical definitions of acute renal failure: procedures, and there was an extended length of ➤➤ Risk—Increase in serum creatinine level X 1.5 or stay/increased nursing care. As coders, we think decrease in GFR by 25%, or UO < 0.5 mL/kg/h that questioning the physician’s clinical judgment is for six hours; Cr rise of 0.3 mg in appropriate inappropriate and that reporting ARF as a secondary circumstance diagnosis is correct. Based on documentation in the record, is coding ARF appropriate? ➤➤ Injury—Increase in serum creatinine level X 2.0 or decrease in GFR by 50%, or UO < 0.5 mL/kg/h for 12 hours From a coding perspective, I agree that you should assign the code if the treating physician clearly ➤➤ Failure—Increase in serum creatinine level X 3.0, decrease in GFR by 75%, or serum creatinine documented ARF and met the criteria of clinically level > 4 mg/dL; UO < 0.3 mL/kg/h for 24 hours, or evaluating and/or treating this condition during an anuria for 12 hours admission in accordance with the UHDDS definition of “other/additional diagnosis.” Coders should not debate clinical scenarios with physicians (e.g., whether a patient had a condition). ➤➤ Loss—Persistent ARF, complete loss of function > four weeks ➤➤ End-stage kidney disease—Loss of function > three months A supplement to Briefings on Coding Compliance Strategies The criteria do not merely progress from normal to abnormal; other factors in the laboratory values also play a role. Jean Stone, RHIT, CCS, coding manager at Lucile Packard Children’s Hospital at Stanford in Palo Alto, Calif., answered the previous question. Shannon McCall, RHIA, CCS, CCS-P, CPC, CPC-I, CEMC, CCDS, director of HIM and coding at HCPro, Inc., A patient is admitted January 3 and undergoes spi- in Danvers, Mass., answered this question, which originally nal surgery that day. No laboratory specimens were appeared on JustCoding.com. drawn until January 4. At that time, the BUN was 24 (normal range is 8–20), and creatinine was 2.09 (normal Which code should I report for atypical small range is 0.64–1.27). A consultation was performed acinar proliferation of the prostate? Is ICD-9-CM January 4, and the physician documented acute renal code 602.3 (dysplasia of prostate) appropriate? failure. What is the correct POA assignment? The ICD-9-CM index does not include a reference for Query the physician to determine whether acute this diagnostic statement. Submit a query regarding renal failure was POA. Appendix I of the ICD-9-CM the clinical significance of the statement, referencing Official Guidelines for Coding and Reporting (POA 602.3 and including its description. Provide the following Reporting Guidelines) indicates that a query is appropri- information in your query: ate if documentation is unclear regarding whether a ➤➤ Clinical indicators, as advised in AHIMA’s practice condition was POA. The provider should clarify the link- brief, “Managing an Effective Query Process” ➤➤ The diagnosis age of signs and symptoms to the acute renal failure, the timing of test results, and the timing of findings. ➤➤ Request for clarification that indicates the lack of a diagnosis code for this diagnosis Laura Legg, RHIT, CCS, revenue control coding consultant at Providence Health & Services in Renton, Wash., Ask which of the following best describes the patient’s answered the previous question. condition: ➤➤ Dysplasia of prostate ➤➤ Neoplasm of prostate—if so, is neoplasm: –– Malignant, primary –– Malignant, secondary –– Malignant, in situ –– Benign –– Undetermined –– Unspecified ➤➤ Other diagnosis regarding atypical small acinar proliferation of the prostate (please specify) _______ ➤➤ Unable to be determined Are you an inpatient coding and compliance expert? Do you enjoy researching inpatient-related coding questions? Do you stay up to date on Medicare transmittals and publications? If you answered “yes” to either question, you’d be a great addition to the Briefings on Coding Compliance Strategies editorial advisory board. Or perhaps you’d simply like to share your insight and experiences. If you’re interested in either opportunity, contact Contributing Editor Lisa Eramo at [email protected]. Coding Q&A is a monthly service to Briefings on Coding Compliance Strategies subscribers. Reproduction in any form outside the subscriber’s institution is forbidden without prior written permission from HCPro, Inc. Copyright © 2012 HCPro, Inc., Danvers, MA. Telephone: 781-639-1872; fax: 781-639-7857. CPT codes, descriptions, and material only are Copyright © 2012 American Medical Association. CPT is a trademark of the American Medical Association. All rights reserved. No fee schedules, basic units, relative values, or related listings are included in CPT. The American Medical Association assumes no liability for the data contained herein. Applicable FARS/DFARS restrictions apply to government use. BCCS, P.O. Box 3049, Peabody, MA 01961-3049 • Telephone 781-639-1872 • Fax 781-639-7857