November 19, 2004
Centers for Medicare & Medicaid Services
ATTN: Janet Samen
Mail Stop C5-05-27
7500 Security Boulevard
Baltimore, Maryland 21244-1850
RE: Medicare Program; Prospective Payment System for Inpatient Psychiatric Facilities; Final Rule (69 Federal Register 66922)
Dear Ms. Samen:
The American Health Information Management Association (AHIMA) has concerns with certain diagnostic and procedural coding requirements outlined in the final rule regarding the Prospective Payment System (PPS) for Inpatient Psychiatric Facilities (IPFs) - published in the November 15, 2004 Federal Register. We recommend that CMS provide clarification of these coding requirements prior to the January 1, 2005 implementation of this prospective payment system.
AHIMA is a not-for-profit professional association representing 50,000 health information management (HIM) professionals who work throughout the healthcare industry. AHIMA's HIM professionals are educated, trained, and certified to serve the healthcare industry and the public by managing, analyzing, and utilizing data vital for patient care in all healthcare settings.
Consistency in medical coding and the use of medical coding standards in the US is a key issue for AHIMA. As part of this effort, AHIMA is one of the Cooperating Parties, along with CMS, the Department of Health and Human Services' (HHS) National Center for Health Statistics (NCHS), and the American Hospital Association (AHA). The Cooperating Parties oversee correct coding rules associated with the International Classification of Diseases Ninth Revision, Clinical Modification (ICD-9-CM). AHIMA also participates in a variety of coding usage and standardization activities in the US and internationally, including the American Medical Association's (AMA's) Current Procedural Terminology® (CPT®) Editorial Panel.
AHIMA is concerned with the coding requirements related to the comorbidity adjustment for malignant neoplasm and the payment adjustment for electroconvulsive therapy treatments:
VI-B-2: Comorbidities (69FR66939)
The final rule states "in order to receive the comorbidity adjustment for malignant neoplasm, inpatient psychiatric facilities (IPFs) will need to code the ICD-9-CM code for the specific malignant neoplasm from the ICD-9-CM chapter 2 codes (140-239) and one of the two ICD-9-CM procedure codes (V58.0 or V58.1) to indicate the treatment modality the patient received."
Codes V58.0 and V58.1, however, are diagnosis, not procedure, codes. Since these diagnosis codes describe the purpose of a healthcare encounter, they can only be reported as the principal diagnosis, not as a secondary diagnosis, according to the ICD-9-CM Official Guidelines for Coding and Reporting. Adherence to the ICD-9-CM Official Guidelines for Coding and Reporting is required under the HIPAA regulations for electronic transactions and code sets.
Codes V58.0 and V58.1, therefore, will never show up as a secondary diagnosis for an admission to an IPF (since the principal diagnosis would be related to the reason they are admitted to an IPF), and, therefore, IPFs will never receive the comorbidity adjustment for malignant neoplasms. To indicate that the patient has received chemotherapy or radiation therapy, an ICD-9-CM procedure code should be reported. The ICD-9-CM procedure codes for chemotherapy and radiation therapy are 99.25 and 92.21-92.29, respectively. AHIMA recommends that IPFs be required to report the ICD-9-CM procedure codes for chemotherapy and radiation therapy in order to receive the comorbidity adjustment for malignant neoplasm.
VI-B-6c: Patients Who Receive Electroconvulsive Therapy (69FR66951)
According to the final rule, IPFs will need to report the ICD-9-CM procedure code for electroconvulsive therapy (ECT) in order to receive additional payments for patients who undergo ECT treatment. Code 90870 is given as the ICD-9-CM procedure code for ECT, which is incorrect. This is a CPT code, not an ICD-9-CM code. The ICD-9-CM procedure code for ECT is 94.27. Reference to the CPT code rather than the ICD-9-CM procedure code will cause confusion as to whether the CPT code or the ICD-9-CM code should be reported. Since the IPF PPS system is based on ICD-9-CM codes, AHIMA recommends that IPFs be required to report the ICD-9-CM procedure code for ECT rather than the CPT code.
If AHIMA can provide any further information, or if there are any questions or concerns with regard to this letter and its recommendations, please contact me at (312) 233-1115, or sue.bowman@ahima.org.
Sincerely,
Sue Bowman, RHIA, CCS
Director, Coding Policy and Compliance
cc: Dan Rode, MBA, FHFMA - VP, AHIMA
Patricia Brooks, RHIA - CMS