At Daymarck, we are pleased that the National Association for Home Care and Hospice (NAHC) is also concerned about CMS' proposed prohibition of reporting any diagnosis codes other than fracture codes in OASIS at M1024. The NAHC Report Article published on Aug. 21 (and attached below) discusses their concerns and urges home health agencies to evaluate the impact of these proposed changes.
According to William Dombi, Vice President for Law at NAHC, "The proposal may affect two to four percent of episodes as much as $200 per episode. That is a material impact that should require CMS to drop this idea or recalibrate all the case mix weights to make sure the change is budget neutral."
We are are pleased to offer a reprint of the article below. Read what Daymarck has to say on this important issue, including our public comment to CMS.
Diagnosis Coding Changes Proposed in 2013 PPS Notice Carry Negative Impact
NAHC Urges Agencies to Review the Rule Change
In the 2013 Prospective Payment System (PPS) proposed rule, the Centers for Medicare & Medicaid Services (CMS) revealed a plan that would result in the prohibition of reporting any diagnosis codes other than fracture codes in OASIS at M1024.
In the July 13 Federal Register notice, CMS stated that when they updated and released Attachment D: Selection and Assignment of OASIS Diagnoses in December 2008 “this guidance was designed to ensure that providers limited the number of diagnoses assigned to M1024.” M1024 replaced M0245 in OASIS C. M0245 was the OASIS data field created to record case-mix diagnoses ICD-9 Coding rules required that V codes be used in primary and secondary diagnoses in order to ensure compliance with Health Insurance Portability and Accountability Act (HIPAA) requirements. According to CMS, an analysis of home health claims found that many home health agencies don’t comply with Attachment D guidance.
CMS Position
According to Attachment D, home health agencies are limited to reporting Fracture, Diabetes, Neuro 1 and Skin 1 codes in M1024. However, Diabetes, Skin 1, and Neuro 1 codes may be reported in M1010 and M1020. Fracture codes are the only codes that may not be reported as primary or secondary diagnosis. As a result, CMS has proposed two enhancements for the HH PPS Grouper:
Restrict M1024 to only permit fracture (V-code) diagnoses codes which according to ICD-9-CM coding guidelines cannot be reported in a home health setting as a primary or secondary diagnosis.
Pair the fracture codes (V-code) with appropriate diagnosis codes to limit the award of grouper points only when these pairings appear in the primary and payment diagnosis fields.
Revise the HHRG logic to permit equivalent scoring when the Diabetes, Skin 1 or Neuro 1 codes are submitted immediately following the V-code in the M1020 position without requiring utilization of the payment diagnosis field.
Shortcomings of CMS Proposal
In its efforts to update the HH PPS case-mix system, CMS had its contractor analyze home health claims and OASIS data from the first five years of the PPS to determine whether the case-mix system required revisions. As a result of this analysis the original diagnostic categories of Diabetes, Neuro, Ortho and Skin were expanded, and several new diagnostic categories were added that included: blindness, blood disorders, cancers, gastrointestinal disorders, heart disease, and hypertension. The data analyzed led to the determination that these additional diagnostic conditions were indicators of home health resource utilization. Much of the information about the impact of these diagnoses on resource utilization was collected from the period of time prior to the implementation of the HIPAA. Therefore, the diagnoses were reflective of coding practices at that time, including the reporting of conditions that were resolved by surgery or recovery, but for which home health patients received aftercare.
For example, such gastrointestinal disorders, as acute appendicitis and cholelithiasis are never conditions for which a Medicare beneficiary would receive home health services. However, prior to HIPAA and the establishment of M0245, and even into 2004, reporting of conditions resolved by surgery as primary and secondary diagnoses was the longstanding practice of home health agencies providing post-surgical care.
These CMS proposed changes to the HHRG will deprive home health agencies of case-mix points and payment for services for care to patients whose conditions are resolved by surgery, disregarding the fact that these diagnoses were found to impact resource use. Included are the majority of gastrointestinal conditions, cancers and orthopedic conditions treated by surgery as well as resolved infections that require post-acute care in the home for (e.g. meningitis). Furthermore, prohibiting reporting of diagnoses that require V code reporting in the primary and secondary fields in OASIS M1024 will eliminate all vehicles for capturing important public health and health planning data sources about underlying medical conditions that require post-acute home health services.
The National Association for Home Care & Hospice (NAHC) has identified a vast array of diagnoses that will no longer be eligible for case-mix points if removed by surgery, including conditions in the following ICD-9 categories: 140-199, 213-234, 320-329, 414, 440,530-562, 564-567, 569 and 570, 574-577, 685, 707, 711, 713, 715 and 716, 720-724, 726 and 727, 730, 731, 733, 741, 785, and 831-838.
NAHC urges home health agencies to evaluate the impact of these proposed changes. To learn more about this proposal and other proposed rule changes and payment updates for 2013 the Federal Register notice can be accessed at http://www.gpo.gov/fdsys/pkg/FR-2012-07-13/pdf/2012-16836.pdf. Comments about this proposal and other changes to home health regulations (F2F encounter, therapy reassessment requirements) must be submitted to CMS by 5PM on September 4, 2012.
According to William Dombi, Vice President for Law at NAHC, "The proposal may affect two to four percent of episodes as much as $200 per episode. That is a material impact that should require CMS to drop this idea or recalibrate all the case mix weights to make sure the change is budget neutral."
We are are pleased to offer a reprint of the article below. Read what Daymarck has to say on this important issue, including our public comment to CMS.
NAHC Report Article
Issue# 2026, 8/21/2012Diagnosis Coding Changes Proposed in 2013 PPS Notice Carry Negative Impact
NAHC Urges Agencies to Review the Rule Change
In the 2013 Prospective Payment System (PPS) proposed rule, the Centers for Medicare & Medicaid Services (CMS) revealed a plan that would result in the prohibition of reporting any diagnosis codes other than fracture codes in OASIS at M1024.
In the July 13 Federal Register notice, CMS stated that when they updated and released Attachment D: Selection and Assignment of OASIS Diagnoses in December 2008 “this guidance was designed to ensure that providers limited the number of diagnoses assigned to M1024.” M1024 replaced M0245 in OASIS C. M0245 was the OASIS data field created to record case-mix diagnoses ICD-9 Coding rules required that V codes be used in primary and secondary diagnoses in order to ensure compliance with Health Insurance Portability and Accountability Act (HIPAA) requirements. According to CMS, an analysis of home health claims found that many home health agencies don’t comply with Attachment D guidance.
CMS Position
According to Attachment D, home health agencies are limited to reporting Fracture, Diabetes, Neuro 1 and Skin 1 codes in M1024. However, Diabetes, Skin 1, and Neuro 1 codes may be reported in M1010 and M1020. Fracture codes are the only codes that may not be reported as primary or secondary diagnosis. As a result, CMS has proposed two enhancements for the HH PPS Grouper:
Restrict M1024 to only permit fracture (V-code) diagnoses codes which according to ICD-9-CM coding guidelines cannot be reported in a home health setting as a primary or secondary diagnosis.
Pair the fracture codes (V-code) with appropriate diagnosis codes to limit the award of grouper points only when these pairings appear in the primary and payment diagnosis fields.
Revise the HHRG logic to permit equivalent scoring when the Diabetes, Skin 1 or Neuro 1 codes are submitted immediately following the V-code in the M1020 position without requiring utilization of the payment diagnosis field.
Shortcomings of CMS Proposal
In its efforts to update the HH PPS case-mix system, CMS had its contractor analyze home health claims and OASIS data from the first five years of the PPS to determine whether the case-mix system required revisions. As a result of this analysis the original diagnostic categories of Diabetes, Neuro, Ortho and Skin were expanded, and several new diagnostic categories were added that included: blindness, blood disorders, cancers, gastrointestinal disorders, heart disease, and hypertension. The data analyzed led to the determination that these additional diagnostic conditions were indicators of home health resource utilization. Much of the information about the impact of these diagnoses on resource utilization was collected from the period of time prior to the implementation of the HIPAA. Therefore, the diagnoses were reflective of coding practices at that time, including the reporting of conditions that were resolved by surgery or recovery, but for which home health patients received aftercare.
For example, such gastrointestinal disorders, as acute appendicitis and cholelithiasis are never conditions for which a Medicare beneficiary would receive home health services. However, prior to HIPAA and the establishment of M0245, and even into 2004, reporting of conditions resolved by surgery as primary and secondary diagnoses was the longstanding practice of home health agencies providing post-surgical care.
These CMS proposed changes to the HHRG will deprive home health agencies of case-mix points and payment for services for care to patients whose conditions are resolved by surgery, disregarding the fact that these diagnoses were found to impact resource use. Included are the majority of gastrointestinal conditions, cancers and orthopedic conditions treated by surgery as well as resolved infections that require post-acute care in the home for (e.g. meningitis). Furthermore, prohibiting reporting of diagnoses that require V code reporting in the primary and secondary fields in OASIS M1024 will eliminate all vehicles for capturing important public health and health planning data sources about underlying medical conditions that require post-acute home health services.
The National Association for Home Care & Hospice (NAHC) has identified a vast array of diagnoses that will no longer be eligible for case-mix points if removed by surgery, including conditions in the following ICD-9 categories: 140-199, 213-234, 320-329, 414, 440,530-562, 564-567, 569 and 570, 574-577, 685, 707, 711, 713, 715 and 716, 720-724, 726 and 727, 730, 731, 733, 741, 785, and 831-838.
NAHC urges home health agencies to evaluate the impact of these proposed changes. To learn more about this proposal and other proposed rule changes and payment updates for 2013 the Federal Register notice can be accessed at http://www.gpo.gov/fdsys/pkg/FR-2012-07-13/pdf/2012-16836.pdf. Comments about this proposal and other changes to home health regulations (F2F encounter, therapy reassessment requirements) must be submitted to CMS by 5PM on September 4, 2012.
