CMS Scales Back on Payment Cuts

Kennedy also says that comments such as those submitted by the Association of Clinical Documentation Improvement Specialists (ACDIS) played a role in ensuring the new code for brain death (code 348.82) became an MCC instead of the a CC, as CMS originally proposed. 

“Similarly, code 294.21 (dementia unspecified with behavioral disturbance) wasn’t going to be a CC, but again because of commenters like ACDIS, CMS made it a CC.”

Shannon McCall, RHIA, CCS, CCS-P, CPC, CEMC, CPC-I, CCDS, director of HIM and coding at HCPro, Inc., in Danvers, MA, the parent company of HealthLeaders Media, also noted the exclusion that was removed related to pressure ulcer coding.

When pressure ulcer site codes (codes 707.00–707.09) are assigned as the principal diagnosis with an additional code for the stage of the pressure ulcer there was a CC/MCC exclusion that would not allow the stage III and stage IV codes (codes 707.23–707.24) to serve as an MCC, she says. This exclusion will be removed for FY 2012 recognizing the stage III and stage IV pressure ulcer stage codes as an MCC when the reason for the admission was the pressure ulcer (i.e., principal diagnosis),  McCall says.

The new, revised, and deleted ICD-9-CM codes have been finalized for FY 2012. (A full listing of the changes is available on the CMS website.)

“They did add a fair number of codes after the proposed rule came out based on the March 2011 ICD-9 Coordination and Maintenance Committee meeting,” McCall says. “Some of the ones that were added were for added specificity, like for postoperative shock to identify whether it was cardiogenic or septic. All of these codes will be considered MCCs.”

CMS also added specificity to the complications associated with central catheter codes to identify whether an infection was considered a local infection due to a central venous catheter vs. a bloodstream infection due to a central venous catheter, McCall says.