1730 M Street, NW, Suite 409
Washington, DC 20036
Phone: 202-659-9440
Fax: 202-659-9422
January 7, 2004
Patricia Brooks, RHIA
Centers for Medicare & Medicaid Services
CMM, HAPG, Division of Acute Care
Mail Stop C4-08-06
7500 Security Boulevard
Baltimore, Maryland 21244-1850
Dear Pat:
The American Health Information Management Association (AHIM a) welcomes the opportunity to provide comments on the proposed procedure code modifications presented at the December 2003 ICD-9-CM Coordination and Maintenance Committee meeting.
Generally support CMS recommendations, with additional comments
Spinal Disc Replacement Devices
AHIMA supports the creation of new codes to capture insertion of spinal disc prostheses. We recommend that a new subcategory be created, rather than adding these codes to subcategory 84.5. This would leave room for expansion in subcategory 84.5.
If these artificial discs are ever removed and replaced, there will need to be a way to code the removal and replacement. The phrase "or replacement" should be added to the descriptions for the "insertion" codes. This would be preferable to including replacement in the code for revision, since the code for revision does not specify the site.
We agree with the commenters who opposed the use of proposed code 84.57 as the default code in the Index. Since this code describes "insertion of other spinal disc prosthesis," it is not appropriate as the default code.
AHIMA disagree with the suggestion that "nonfusion arthroplasty" be added as an Index entry and/or inclusion term. The term "nonfusion arthroplasty" may be used by physicians to describe procedures other than insertion of artificial spinal disc prostheses.
Automatic Implantable Cardioverter/Defibrillator (AICD) Check
AHIMA supports the creation of a unique code for AICD checks, and we agree with the suggestion that Excludes notes be added under the new code and under code 37.26 to ensure that these codes are used correctly.
Insertion of Neurostimulator Components
AHIMA supports the creation of three new codes for insertion of neurostimulator pulse generators and the redefinition of existing neurostimulator codes. We also support the revision of the title of code 86.05 to allow removal of neurostimulator pulse generators to be classified to this code.
A default code will need to be determined for those instances when the insertion of the pulse generator is not specified as single array or dual array.
As was mentioned during the meeting, "or replacement" needs to be added to the new codes for insertion of neurostimulator pulse generator to allow coding of the procedure when the device is replaced.
Axial Flow Left Ventricular Assist Device
We support CMS' recommendation, which was to not create new codes for new ventricular assist devices, but to broaden existing codes to cover new types of devices. The procedure performed to insert the device is essentially the same, so it is not necessary to create device-specific codes. We concur with those commenters who indicated the medical record documentation might not adequately identify the specific device such that coders would be able to select an appropriate device-specific code.
Intravascular Ultrasound
AHIMA supports the CMS recommendation to create new codes for intravascular ultrasound procedures. We agree with the suggestion made during the meeting that the term "vessels" be used in the code titles instead of "arteries," since intravascular ultrasound can be performed on both arteries and veins. We also agree with the suggestion that the new code be specifically excluded from existing codes 37.28 and 88.72.
Pressurized Treatment of Venous Bypass Graft with Pharmaceutical Substance for Prevention of Vein Graft Failure
Although we are not convinced that treatment of a harvested vessel prior to a bypass procedure should be specifically identified by an ICD-9-CM code, and could be considered an inherent part of the surgical procedure, we recognize that there is probably a need to identify instances when this step is performed to assess clinical efficacy of this treatment of the harvested vessel. We recommend that the term "pressurized" be included in the code title so as to clearly indicate that this code is limited to this specific service. A "code also" note should be added under the appropriate bypass graft codes to ensure that an additional code is assigned for this service when appropriate. It would be beneficial to add "E2F Decoy" as an inclusion term under the new code, rather than just including this term in the discussion of the new code in Coding Clinic for ICD-9-CM . By adding this as an inclusion term, coders will recognize that this code is the appropriate one when they see this term documented in the medical record.
Unrelated Allogeneic Bone Marrow Transplantation
AHIMA agrees with CMS' recommendation not to create new codes to distinguish between related and unrelated donors for allogeneic bone marrow transplantation. Whether or not the donor is related is irrelevant to the procedure being performed. As noted by CMS, other transplant codes do not distinguish between related and unrelated donors.
Support CMS recommendations as presented, with no additional comments
Laparoscopic Adjustable Gastric Procedure
Addenda
We support the proposed addenda revisions. We are particularly pleased with the revision of the titles of the codes for coronary bypass grafts so that "aorto" becomes a non-essential modifier, thus allowing the use of these codes when the aorta is not involved.
Thank you for the opportunity to comment on the proposed procedure code revisions. If you have any questions, please feel free to 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, Vice President, Policy and Government Relations, AHIMA
| Source: AHIMA Policy and Government Relations (January 2004) |