Coding, Classification & Reimbursement

Skilled Nursing and PCS coding

  • 1.  Skilled Nursing and PCS coding

    Posted 20 days ago
    Hi, I am trying to get my mind around how LTC facilities will potentially submit PCS codes on the MDS effective October 1, 2019.
     

    LTC has not used PCS codes and it seems odd to require LTC to locate and submit a PCS code for services provided elsewhere!  

    From the Federal Register:

    https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-09015.pdf

    "The MDS item I0020 would require facilities to select a primary diagnosis from a pre-populated list of primary
    diagnoses representing the most common types of beneficiaries treated in a SNF, while item
    I8000, if used to assign residents to clinical categories, would require facilities to code a specific
    ICD-10-CM code that corresponds to the primary reason for the resident's Part A SNF stay. As
    indicated above, we are also proposing that providers would code a specific ICD-10-PCS code in
    the second line of item I8000 when surgical information from the prior inpatient stay is
    necessary to assign a resident to a clinical category."



    As far as day of transfer to SNF from acute hospital, is the PCS code already assigned (and could be shared with SNF) or does PCS code assignment typically take a few days post discharge from acute hospital?

    If you want to comment back to CMS (by June 26th) that this new requirement will increase burden on SNFs (either in training on PCS for LTC, or time spent trying to get the PCS code from the acute hospital), please submit your comments back to CMS (instructions below came from above Federal Register):


    Comments, including mass comment submissions, must be submitted in one of the
    following three ways (please choose only one of the ways listed):

    1. Electronically. You may submit electronic comments on this regulation to
    http://www.regulations.gov. Follow the "Submit a comment" instructions.

    2. By regular mail. You may mail written comments to the following address ONLY:
    Centers for Medicare & Medicaid Services,
    Department of Health and Human Services,
    Attention: CMS-1696-P,
    P.O. Box 8016,
    Baltimore, MD 21244-8016.

    Please allow sufficient time for mailed comments to be received before the close of the
    comment period.

    3. By express or overnight mail. You may send written comments to the following
    address ONLY:

    Centers for Medicare & Medicaid Services,
    Department of Health and Human Services,
    Attention: CMS-1696-P,
    Mail Stop C4-26-05,
    7500 Security Boulevard,
    Baltimore, MD 21244-1850

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    Bill Roush, RHIT, AHIMA-Approved ICD-10-CM Trainer
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  • 2.  RE: Skilled Nursing and PCS coding

    Posted 20 days ago

    What about the aftercare codes we currently use...seems to me those explain the care LTC facilities are providing the resident, rather than procedure codes. 

     






  • 3.  RE: Skilled Nursing and PCS coding

    Posted 20 days ago
    Yes the Aftercare Z codes are perfect for LTC, seems like CMS is trying to slip PCS into LTC and that will be a rather gigantic change!

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    Bill Roush, RHIT, AHIMA-Approved ICD-10-CM Trainer
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  • 4.  RE: Skilled Nursing and PCS coding

    Posted 19 days ago
    Thanks for the heads-up William.  I surmise only hospitals with CDI practioners and/or perform concurrent coding will have the PCS code available prior to/at discharge.  This will indeed be an administrative burden on hospital staff.  I could also anticipate errors if CDI/coding staff are asked to perform precipitously, as it's use is not hospital based.

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    Sheila Goethel
    Coding Services Senior Manager
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  • 5.  RE: Skilled Nursing and PCS coding

    Posted 14 days ago
    Hi, it looks like the American Association of Nurse Assessment Coordination (AANAC) - the MDS Nurse's Association - is commenting

    back to CMS that there are definite burdens for LTC if they are mandated to use PCS codes on the MDS starting October 1, 2019.

    Some of the burdens that I can see being placed on LTC are:

    $120 for a PCS code book per building (assuming they are not told by their company to "just google the PCS code")

    Time spent per MDS locating the correct PCS code based on Operative Report (would this be 15 minutes per MDS roughly?).

    Training time for SNF HIM and MDS in  the current commonly used PCS codes (during the Acute stay) for the LTC resident.

    If SNFs elect to NOT use a PCS code book and rather choose to chase down the exact PCS code used in Acute, this will involve staff time

    both in the SNF and in the ROI department for the Acute.  This could conceivably delay timely completion of the MDS.

    I work as a Consultant in California, there are roughly 1,100 SNF buildings.  California eliminated the requirement for SNF HIM to hold

    AHIMA credentials (or have access to a Consultant) in the mid 90's (it was slashed from Title 22 for some reason).

    So we have mostly non-credentialed coders in the California SNFs!








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    Bill Roush, RHIT, AHIMA-Approved ICD-10-CM Trainer
    ------------------------------