So I have had a little time to think on my response before posting, as my answer will be multilayered. Also, my name is not Thomas, although I like Edison's quote at the bottom of my signature line
First things first, I work for a payer so how we handle Risk Adjustment is a bit differently than on a provider side. That being said, we are all still dealing with the basic rules of Risk Adjustment, however the reporting might differ a bit.
Second, and I missed the "nephropathy" when I read the original poster's entry (a case of the Mondays perhaps), however my argument will still stand. As you probably know, Diabetes is one of the 9 Common Chronic Conditions that can be coded with little to no documentation support (meaning no need of other MEAT or TAMPER). In my eyes that ONLY pertains to the "vanilla" DM or E11.9/E10.9, and not any associated or linked casual relationship with DM. I will need to dig up my references (busy week for me), but I have references on this. For me to pick up such a linked condition, the nephropathy/neuropathy must have some type of MEAT or TAMPER associated with it or I will grab the vanilla DM instead along with an EDU note. This is also based on CMS audit results and a former CMS RADV level 2 auditor, aka my manager. Again, I will see if I can dig up references as support, but I just don't have time right now.
Third, while I do not think you are wrong
@rmwinder , be careful with using such a broad brush as Guideline 19 for everything.
Yes, we need to follow what the provider documents, and
yes we all follow CMS and AHA Coding Guidelines, however there are some grey areas that can be left up to some interpretation. Like
@Munzueta said, I would never code a Malignant Neoplasm code solely based on the provider listing the condition and otherwise NO MEAT. There is a specific Coding Clinic on this (again busy busy week for me) which I will need to pull up some other time.
Fourth, and I think this is also important. I recently plugged into an AAPC webinar on Risk Adjustment, and the presenter talked about the amount of Risk your company is willing to take. We know there are grey areas in coding, as everything is not black/white, however on those harder topics the organization you work with will need to take a stance on how "risky" they want to be in terms of Risk Adjustment. While you might "get away" with a substandard documentation of MEAT on some conditions, CMS will sometimes go back and audit you several years back. Health Plans recently received a HUGE Contract RADV audit with record retrieval back from 2013-2014, and I am sure you can imagine the problems such an old audit can potentially cause. I got more on this, but suffice to say, when CMS is out for blood, they are OUT for blood.
Lastly, thank you for challenging me
@rmwinder as this helps keep me on my toes and keep my information straight.
I hope this is helpful!