"The problem is that doesn't allow for counting by utilization days because observation time doesn't accrue inpatient utilization days," Hoys says. "There will need to be significant clarification about when the time starts for this 'two midnights.' Otherwise, there is going to be a lot of confusion."
Under the Affordable Care Act, CMS is required to penalize hospitals in the lowest-performing 25% for eight hospital-acquired conditions (HACs). Beginning in 2015, those facilities would receive only 99% of what they would otherwise be paid under IPPS. CMS plans to divide the HACs into two domains. The first would include:
The second domain would include rates of central line-associated bloodstream infections and catheter-associated urinary tract infections. CMS will calculate a domain score for each hospital, with each domain accounting for 50% of the score. CMS will also factor in patient's age, gender, and comorbidities so that hospitals serving a large proportion of sicker patients would not be unfairly penalized. CMS will not create new or modify the existing (HACs), which surprised Kennedy.
"I find it interesting that the titles of two HACs, catheter-associated urinary tract infections and vascular catheter-associated infection, cannot be coded with the codes defining these HACs if documented by a provider," Kennedy says. He believe that the titles of these HACs should be changed to "symptomatic urinary tract infections due to an indwelling urinary catheter" and "infection due to a central venous catheter" to reflect the documentation necessary to identify and code these HACs.
Kennedy hopes providers comment upon these, especially in light of advice written in the Medicare Provider Quarterly Compliance Newsletter in April 2012 and in Coding Clinic for ICD-9-CM, 2nd Quarter, 2012, pages 21-22.