Home Health & Hospice Week

If you’re confused about the intersection of face-to-face requirements and diagnosis coding, you’re not alone — and the Centers for Medicare & Medicaid Services is getting to work on the issue.

Question: “Have you had any updates from CMS on guidance for review of the reason for the face-to-face encounter compared to the primary diagnosis on the claim?” reads a question from the latest round of Home Health and Hospice Coalition Questions and Answers from HHH Medicare Administrative Contractor Palmetto GBA. “Agencies must comply with ICD-10 coding conventions so they must list the diagnoses codes in a certain order which sometimes results in a diagnosis code that is not the primary reason for home health service being listed as the primary diagnosis. For example, hypothyroidism needs to be coded before dementia, and hypertension must be coded before congestive heart failure. It is our understanding that F2F encounter diagnosis with those on the plan of care, not those on the claim since the ICD-10 coding conventions apply only to the claim,” the Q&A says.

Answer: “A workgroup will be formed consisting of [the National Association for Home Care & Hospice], technology/ vendors, providers, Palmetto GBA, state association members, CGS and NGS to discuss the need for ICD 10 code being on the plan of care,” Palmetto responds. “The diagnosis code (ICD code) was a requirement from the CMS form 485, which was made obsolete decades ago. The group will discuss the feasibility of removing the ICD 10 code from the plan of care.”