Coding, Classification and Reimbursement

PDPM in LTC - new Final Rule addresses ICD-10

  • 1.  PDPM in LTC - new Final Rule addresses ICD-10

    Posted 20 days ago
      |   view attached

    Hi, CMS has posted a Final Rule relative to:

     

    Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program and Value-Based Purchasing Program for Federal Fiscal Year 2020

     

    Found here:

     

    https://s3.amazonaws.com/public-inspection.federalregister.gov/2019-16485.pdf

     

    This document is scheduled to be published in the Federal Register on 08/07/2019 and available online at https://federalregister.gov/d/2019-16485, and on govinfo.gov

     

    I have attached a PDF.

    Any assistance in interpretation would be greatly appreciated!

     

    There are 76 references to ICD-10 in the 364 pages, here is some of the flavor:

     

    Comment: Some commenters commented on an aspect of the PDPM established in the

    FY 2019 SNF PPS final rule (83 FR 39162), specifically, the use of ICD-10 codes in section

    I0020B to assign patients to clinical categories used for categorization in the PT, OT, and SLP

    components. Commenters noted a possible discrepancy between the American Health

    Information Management Association (AHIMA) guidance and MDS guidance with regard to

    how to code the "principal diagnosis" in I0020B. Commenters requested that CMS work with

    AHIMA or other professional coding organizations to ensure that coding instructions for the

    MDS are consistent with all relevant ICD-10 coding rules and guidelines.

    Response: We appreciate these comments and will work to ensure that any guidance

    provided to SNFs on ICD-10 coding practice aligns with best practices in this field.

    Comment: A commenter encouraged CMS to ensure that, for SNFs, the subregulatory

    process to update ICD-10 mappings and lists aligns with the process used in the context of the

    Inpatient Rehabilitation Facility (IRF) PPS, where the commenter understands providers globally

    have accepted the changes.

    Response: We agree and believe the proposed subregulatory update process for SNFs

    aligns with the process used in the IRF PPS to update the tier comorbidities list and the code lists

    used for the IRF presumptive compliance methodology. As we noted in the proposed rule, the

    subregulatory update process used in the IRF PPS was one of the models we used to develop the

    proposed subregulatory process for updating ICD-10 code mappings and lists in the SNF PDPM.

    Comment: A commenter noted that, in addition to annual implementation of new and

    revised ICD-10-CM codes, the conventions and instructional notes in the ICD-10-CM code set

    and the ICD-10-CM Official Guidelines for Coding and Reporting are also updated on October 1

    of each year. The commenter stated that compliance with the current ICD-10-CM codes,

    conventions, instructions, and the Official Guidelines for Coding and Reporting is required for

    all healthcare settings under the Health Insurance Portability and Accountability Act (HIPAA).

    The commenter recommends that CMS ensure any appropriate updates to the ICD-10-CM codes

    associated with PDPM clinical categories and comorbidity lists that are necessitated by changes

    to the ICD-10-CM conventions, instructions, or guidelines are included in the proposed

    subregulatory process.

    Response: We agree and will ensure that any appropriate updates to the ICD-10-CM

    codes associated with PDPM clinical categories and comorbidity lists that are necessitated by

    changes to the ICD-10-CM conventions, instructions, or guidelines are included in the proposed

    subregulatory update process.

    Comment: Some commenters provided specific recommendations on revisions to the

    current mappings available on the CMS website, such as changes in code assignments to clinical

    categories and the comorbidities list, additional comorbidities, and other such changes.

    Response: We appreciate the commenters' suggestions for changes in the current ICD-10

    mappings and lists. However, because we consider these suggestions to be outside the scope of

    the current rulemaking, we are not addressing them in this final rule. We will certainly consider

    these suggestions as part of our future rulemaking efforts, or for inclusion in our updated

    mappings in case certain suggestions may be characterized as non-substantive in nature.

    After consideration of the comments received, for the reasons discussed in this final rule

    and in the FY 2020 SNF PPS proposed rule, we are finalizing as proposed, without modification,

    the process discussed above for updating the ICD-10 code mappings and lists associated with

    PDPM. As proposed, the subregulatory process for updating the ICD-10 codes used under the

    PDPM will take effect beginning with the updates for FY 2020. When the proposed rule was

    issued, the ICD-10 code mappings and lists available for download from the SNF PPS Web site

    (https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/SNFPPS/PDPM.html).

    reflected the adoption of the ICD–10 Coordination and Maintenance Committee's draft changes

    to the ICD–10 medical code data sets, effective October 1, 2018, and we stated that these would

    constitute the baseline for any future updates to the mappings and lists using the update process

    finalized in this rule. Effective October 1, 2019, these baseline mappings and lists will be

    updated to incorporate, as appropriate under the process finalized in this rule, updates to the

    ICD-10 code sets issued by the ICD–10 Coordination and Maintenance Committee in June 2019

    to be effective October 1, 2019. We plan to post these updated mappings and lists on our

    website prior to October 1, 2019 (and after issuance of this final rule) so that the public can

    access them prior to the effective date

     

     



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    Bill Roush, RHIA, BSHI, AHIMA-Approved ICD-10-CM Trainer
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    Attachment(s)

    pdf
    2019-16485.pdf   1.58MB 1 version


  • 2.  RE: PDPM in LTC - new Final Rule addresses ICD-10

    Posted 19 days ago
    Hi CMS has posted a great Fact Sheet here:

    https://www.cms.gov/newsroom/fact-sheets/fiscal-year-2020-payment-and-policy-changes-medicare-skilled-nursing-facilities-cms-1718-f

    Sub-Regulatory Process for International Classification of Diseases, Tenth Version (ICD-10) Codes Revisions
    CMS' Patient Driven Payment Model (PDPM) will be effective October 1, 2019 under the SNF Prospective Payment System (PPS) for classifying patients in a covered Medicare Part A SNF stay. The PDPM utilizes ICD-10 codes to classify SNF patients into certain payment groups. Each year, the ICD-10 codes and guidelines are revised in a variety of non-substantive ways, such as a single code being split into two more specific codes.  To help ensure SNFs have the most up-to-date ICD-10 code information as soon as possible, in the clearest and most useful format, CMS is finalizing a sub-regulatory process for making non-substantive changes to the list of ICD-10 codes used to classify patients into clinical categories under the PDPM.  This sub-regulatory process aligns with similar policies in the SNF PPS and the Inpatient Rehabilitation Facility (IRF) PPS.  The SNF PPS already uses a sub-regulatory process to make non-substantive updates to the list of Healthcare Common Procedure Coding System (HCPCS) codes that are subject to consolidated billing.  In addition, the IRF PPS uses a similar sub-regulatory updating process for the IRF tier comorbidities list and for updating the ICD-10 code lists used for the IRF presumptive compliance methodology.

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    Bill Roush, RHIA, BSHI, AHIMA-Approved ICD-10-CM Trainer
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