Watch for forthcoming guidelines.
While much of the logic in the ICD-10 code set is comfortably similar to that of ICD-9, one area is poised to give home health agencies and hospices trouble — selecting the correct seventh character.
Don’t expect Medicare Administrative Contractors to cut you any slack in this area during the transition. “ICD-10 codes may require a 7th digit,” MAC National Government Services stresses in a Sept. 14 email to providers. “NGS expects providers to use the 7th digit that describes the encounter information associated with the treatment on the claim.”
Old way: In preparing for the ICD-10 transition, your coders likely have been told over and over that they will never assign seventh digit “A” indicating initial encounter.
New way: Originally, home health coding experts believed that seventh character “A” would never be appropriate in home health because these patients had already been seen for treatment in another setting. However, the National Association for Home Care & Hospice recently reported that the organizations responsible for the official ICD-10 coding guidance issued a clarification requiring home health agencies to indicate an “A” (initial encounter) in the seventh character for some ICD-10 codes, according to its member newsletter.
“An ‘A’ in the seventh character should be used for any encounter where the patient is still receiving active treatment for the clinical condition, including home health. While in many cases this would not apply to home health, there are times where it could, such as antibiotic treatment for a postop infection,” NAHC says.
In the section on coding for pathologic fractures in the ICD-10-CM Official Guidelines for Coding and Reporting, coders will find the following instruction: “While the patient may be seen by a new or different provider over the course of treatment for an injury, assignment of the 7th character is based on whether the patient is undergoing active treatment and not whether the provider is seeing the patient for the first time.”
Tip: Guidance from the AHA Coding Clinic for ICD-10-CM and ICD-10-PCS indicates that home care coders still should use seventh character “D” as the default for fractures.
And in the section on the application of seventh characters in Chapter 19, the guidelines also advise “For complication codes, active treatment refers to treatment for the condition described by the code, even though it may be related to an earlier precipitating problem. For example, code T84.50XA, Infection and inflammatory reaction due to unspecified internal joint prosthesis, initial encounter, is used when active treatment is provided for the infection, even though the condition relates to the prosthetic device, implant or graft that was placed at a previous encounter.”
Tip: Examples provided by the Coding Clinic include a patient receiving IV antibiotics in another care setting after the hospital for an infected joint replacement. In this case, because the care was ongoing, the seventh character would be “A,” the Coding Clinic says. Another example describes a patient three years post-op from a gastric bypass whose wound dehisced. The patient leaves the hospital for another care setting. In this case, seventh character “A” is appropriate because the patient is receiving ongoing care provided in the setting following the hospitalization.
None of these examples are home healthspecific. However, a question was submitted to the Coding Clinic regarding a patient with an infected joint replacement being admitted to home health with IV antibiotics. Seventh character “A” is also appropriate in this case, according to the Coding Clinic.
The Board of Medical Specialty Coding and Compliance has approached the American Health Information Management Association (AHIMA), NAHC, and the Centers for Medicare & Medicaid Services regarding the interpretation. CMS indicates that it will stand by the guidance, but has not yet issued an official interpretation, says coding expert Lisa Selman-Holman of Selman- Holman & Associates, CoDR — Coding Done Right and Code Pro University in Denton, Texas.
Note: For more information on ICD-10 coding, subscribe to Eli’s Home Health Coding & OASIS Expert at at https://www.aapc.com/codes/ .