Home Health & Hospice Week

Providers remain confused about diagnosis coding guidance.

A heavy new burden imposed on home health agencies by the new Attachment D just got lighter.

Corrections to the OASIS User’s Manual’s newly revised section on diagnosis coding address questions HHAs have about plan of care requirements, CMS officials indicated in the Feb. 18 Open Door Forum for home care providers.

The problem: On page four of Attachment D, CMS instructs HHAs to “ensure that the diagnosis under consideration is addressed in the home health plan of care and that the diagnosis under consideration affects the patient’s responsiveness to treatment and rehabilitative prognosis.”

This requirement has thrown agencies for a loop. Two callers to the forum requested clarification on the matter from CMS. For example, an HHA caller from Georgia asked whether in a case where a patient is receiving therapy only and has diabetic neuropathy, it is OK that the plan of care does not include interventions for the neuropathy, even though it will clearly affect the treatment.

The solution: CMS’s Lori Anderson and Kathy Walch didn’t answer the callers’ questions outright, but referred them to one of their recent corrections regarding secondary diagnoses (see Eli’s HCW, Vol. XVIII, No. 8, p. 58). “I think it will answer your question,” Anderson said of the revision.

HHAs were frustrated by CMS’s failure to answer the question forthrightly. The callers’ questions “were not answered appropriately,” says Mary St. Pierre with the National Association for Home Care & Hospice. CMS should have said clearly that secondary diagnoses that don’t have specific interventions in the POC could be included in coding.

But home care coders should rest assured that the recent corrections do address the issue, experts say.

The correction changes the bullet to say agencies should “ensure that the secondary diagnosis under consideration includes not only conditions actively addressed in the patient’s plan of care but also any comorbidity affecting the patient’s responsiveness to treatment and rehabilitative prognosis, even if the condition is not the focus of any home health treatment itself.”

This clears up confusion over the requirement in Attachment D that said each diagnosis must be addressed in the plan of care, says coding expert Lisa Selman-Holman of Selman-Holman & Associates in Denton, Texas.

The old language was in opposition to Chapter 8 and other official coding guidance, Sel-man-Holman notes. CMS has now acknowledged that other diagnoses should be listed as secondary when they may affect the POC, even if no treatment is needed.

“Our take ... is that CMS is reverting back to longstanding instructions for identifying diagnosis codes,” St. Pierre tells Eli.

Don’t Get Distracted By Severity Ratings

Walch offered more Attachment D-related guidance in the forum as well. CMS has received numerous questions about sequencing for secondary diagnoses via the Ask OasisAttachD@cms.hhs.gov mailbox.

“CMS expects HHAs to comply with the longstanding home health policy of listing the patient’s secondary diagnoses on the OASIS to best reflect the seriousness of the patient’s condition and to justify the services and disciplines required by the condition,” Walch said.

Tip: And home health coders shouldn’t use severity ratings for secondary diagnoses when deciding on sequencing. “These are separate items,” Walch said.

HHAs may have to wait a while for a corrected Attachment D file from CMS. CMS will issue a new version “at some future point,” Anderson said.

Resource: The corrections and an Attach-ment D link are at www.cms.hhs.gov/center/hha.asp.

PPS Adjustments Cause Trouble

The recent adjustment process that corrected payments for errors under the prospective payment system has not gone without hitches. In addition to processing delays (see Eli’s HCW, Vol. XVIII, No. 7, p. 52), providers are reporting claims reconciliation confusion.

For example: An HHA caller from Wiscon-sin told CMS that the agency was receiving letters requesting checks for each adjustment, but the funds had already been recouped electronically. The letters are causing confusion, she complained.

And don’t forget that the PPS adjustments aren’t done. CMS will fix another PPS problem regarding episodes with 20 or more therapy visits in July, CMS’s Wil Gehne reminded listeners (see Eli’s HCW, Vol. XVIII, No. 6, p. 44).

However, agencies wanting to receive their correct reimbursement for claims affected by the error will have to bring them to their intermediaries’ attention after the correction date, July 6, Gehne instructed.