Home Health & Hospice Week

Final rule contains some last-minute reshuffling.

The addition of dysphagia codes isn’t the only diagnosis coding change in the 2020 home health final rule.

The Centers for Medicare & Medicaid Services adds six dysphagia symptom codes to the Patient-Driven Groupings Model case mix system in the 2020 final rule (see Eli’s HCW, Vol. XXVIII, No. 42). But CMS also moves some codes to different clinical groups based on comments on the proposed rule. Commenter-sparked changes include codes for:

• Diabetes. CMS reassigns E11.9 (Type 2 diabetes mellitus without complications) from the Medication Management, Teaching and Assess­ment–Other clinical group to the MMTA-Endocrine group. “Commenters … stated that if this diagnosis code was primary, this would mean that the patient is newly diagnosed,” CMS says in a change table in the rule. CMS also moves E10.9 (Type 1 diabetes mellitus without complications) and E13.9 (Other specified diabetes mellitus without complications) to MMTA-Endo “to be clinically consistent.”
• Osteoporosis. CMS moves M81.0 (Age-related osteoporosis w/o current pathological fracture) from the MS Rehab to the MMTA-Other group. “Clinically, if this is reported as the principal diagnosis, the primary reason for home health services would be for MMTA,” CMS explains.
• Hypertension plus ulcers. CMS moves a group of codes for chronic venous hypertension with ulcer of low extremities (I87.311-I87.333) from the MMTA-Cardiac clinical group to the Wound clinical group. “This should be grouped under the Wound group given the ulcer is included in the code description,” the final rule notes.
• Trach complications. CMS moves five tracheostomy codes (J9501-J9509) from the MMTA-Respiratory group to the Complex Nursing Interventions group. “All complications of ostomies [should] be included in the Complex group,” commenters told the agency after the proposed rule.
• Post-op complications. CMS shifts T81.49XA/D/S (Infection following a procedure, subsequent encounter) from the MMTA-Infectious Disease/Neoplasms/Blood-forming Diseases to the Wound group. “ICD-10-CM coding instructions … for T81.4 state that these codes indicate a wound abscess following a procedure,” the final rule points out. Likewise, CMS moves T81.89XA/D/S from the MMTA Other to the Wound group. “ICD-10-CM does not provide a specific code to describe a non-healing surgical wound, so T81.89XX would be the appropriate code to assign,” CMS explains.
• Surgical aftercare. CMS adds Z48.814 (Encounter for surgical aftercare following surgery on the teeth or oral cavity) to the MMTA-Aftercare group. It was previously not assigned to any case mix group. CMS also adds Z48.49 (Other specified surgical aftercare, NEC) to the MMTA-Aftercare group, noting that it “would warrant inclusion.”
• Venous insufficiency. CMS reassigns I87.2 (Venous Insufficiency (chronic/peripheral)) from the MMTA-Cardiac to MMTA-Wound group.

CMS also drops one code from the MMTA- Infectious group — T81.40XA/D/S (Infection following a procedure, unspecified, initial encounter). “There are more specific codes that could be reported to indicate an infected surgical wound,” CMS says.

And CMS shoots down a number of commenters’ suggestions as well, as listed in Table 12 of the rule (see story, p. 334).

Finally, a list of clinical group changes CMS makes to “ensure consistency” after its examination of the groups are in Table 13. CMS adds six codes (five to MMTA groups, one to MS Rehab) and moves four others, including two — T84.89XA/D/S (Other specified complication of internal orthopedic prosthetic devices, implants and grafts) and T87.89 (Other complications of amputation stump) from the MMTA-Other to the Wound group.

Note: The rule is at www.govinfo.gov/content/pkg/FR-2019-11-08/pdf/2019-24026.pdf.