Home Health & Hospice Week

Diagnosis Coding:

HIPAA Enforcement Will Include V Codes

If you haven't set your training schedule for V and E diagnosis codes yet, now is the time before you suffer reimbursement hits come October.

In four months, home health agencies must comply with all ICD-9 coding conventions, including using V and E codes as primary diagnoses where appropriate, the Centers for Medicare & Medicaid Services reminded participants in the June 4 Open Door Forum for home health and durable medical equipment.

The Health Insurance Portability and Accountability Act requires electronic transactions - including reimbursement claims - to comply with ICD-9 rules along with other standards. And CMS requires the diagnoses on the claim, OASIS assessment and plan of care to match, said a CMS official.

The HHS Office for Civil Rights will enforce HIPAA rules for HHA claims, CMS added.

When use of V and E codes becomes a requirement, CMS will add a new OASIS item, M0245, to make sure HHAs continue to receive proper payment for their patients (see Eli's HCW, Vol. XI, No. 28, p. 226). To avoid significant diagnosis code-related losses after the change, agencies must train clinicians and coders on this new item, experts warn.

 "While CMS will require agencies to use M0245, they don't have to use the rest of the OASIS changes the agency proposed last December unless they want to, a CMS official confirmed."

 

While CMS will require agencies to use M0245 and V and E codes, they don't have to use the rest of the OASIS changes the agency proposed last December unless they want to, a CMS official confirmed in the forum.

CMS made five main changes to the OASIS assessment in an effort to reduce agencies' OASIS burdens:

1. Moved 18 demographic items to a patient tracking sheet so clinicians have to collect them only once, unless the items change.

2. Eliminated a handful of items on environmental hazards.

3. Slashed items on followup assessments 71 percent, requiring only the 23 "Moo" questions determining payment and three items to match records.

4. Added new skip patterns for items related to ulcers, wounds and urinary infections.

5. Added M0245.

CMS will require HHAs to implement only the last change, use of M0245, in October. The reduced OASIS data set is at www.cms.hhs.gov/oasis/oasisdat.asp.

Meanwhile, CMS is working on service area problems reported under the Home Health Quality Initiative's Home Health Compare Web site, a CMS staffer said in the forum. HHAs continue to find their service areas aren't accurately represented on the site. Home Health Compare lists agencies' patient outcomes in eight pilot states and posts demographic information for all agencies nationwide.

To combat the service area problem, CMS will base service areas on zip codes reported in M0060 for the past one year instead of two years, the official explained. CMS is working on other solutions with state associations to make the service area more accurate, but it probably won't be able to use certificate of need information from states.

Once all providers use the new 855 enrollment form to enroll and reenroll in Medicare, CMS should be able to use service areas reported on that form. Unfortunately, all providers won't be using the form until 2006.