Medicare Compliance & Reimbursement
CMS Dismisses Attachment D Concerns
Sequencing, risk adjustment not harmed by new guidance on secondary diagnosis coding, CMS official maintains. When the Centers for Medicare & Medicaid Services revised its official guidance on diagnosis coding, known as Attachment D to the OASIS User's Manual, home health agencies were confused over what they perceived as new instructions on sequencing and M0246. Chief concerns were when to use case mix codes in M0246 when there was a V code in M0230 and what happens to risk adjustment if the code that used to go in M0246 isn't there. At the recent National Association for Home Care & Hospice March on Washington conference in Washington,D.C., CMS's Lori Anderson said agency officials found the controversy surprising. Attachment D merely reiterates longstanding coding guidance from CMS on sequencing and adds some new opt-outs that should simplify M0246 coding, Anderson insisted. Old way: CMS used to direct agencies to put a case mix code in M0245 (the item before it was changed to M0246 last year) any time a V code replaced it in M0230. New way: Now CMS tells agencies to put a case mix code in M0246 in only three specific circumstances: when the replaced case mix code is in the Diabetes, Skin 1, or Neuro 3 PPS diagnosis groups; when the V code replaces a case mix code that is a resolved condition; and when the V code replaces a fracture code. "Nothing [bad] is going to happen if you code M0246" under the old rules, Anderson noted in the session. It's merely a waste of time to code M0246 when the payment system will pick up the case mix points elsewhere due to changes made in the prospective payment system refinements that took effect in January 2008. "There simply isn't a need to code M0246" in most cases, Anderson told attendees. Think of coding the item as "optional," except in the three narrow circumstances laid out by CMS. No worries: Failing to have the case mix code in M0246 shouldn't affect risk adjustment for outcomes either, Anderson maintained. You should list the case mix code in M0240 on the OASIS form anyway, and the more complex PPS system should pick it up for risk adjustment there, she said. As for sequencing guidance, that hasn't changed,Anderson insisted. Home health coders should place diagnoses in the order that best reflects the seriousness of the patient's condition, she advised.
Medicare Compliance & Reimbursement
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