This condition does seem to meet HAC the criteria of occurring commonly and can cause a significant increase in resource consumption in order to treat this condition, she says. It is also labeled as a complication and comorbidity. However, HACs must also be reasonably preventable, according to evidence-based research, and this has also kept other conditions, such as ventilator-associated pneumonia, off the list in the past.
The addition of the surgical site infections from CIEDs seems to follow along with the inclusion of other site infections already on the HAC list, especially given an increased focus on ensuring sterile environments to avoid contamination of a primary infection at the time of placement of such devices, McCall says.
Coding and documentation adjustment
CMS expects the FY 2013 proposed documentation and coding adjustment (DCA) to net an aggregate increase of 0.2%. The DCA was originally established at the time CMS implemented MS-DRGs. It was thought that due to the increased need for specificity, facilities would focus attention on improvements to documentation. The shift in coding would not necessarily indicate that facilities were treating sicker patients than they had previously, only that they were now better able to capture that specificity. The last two years, the DCA has resulted in a payment offset of -2.0% and -2.9%.
"In good news, the documentation and coding adjustment actually works in the provider's favor this year, increasing reimbursement by 0.2%," Kennedy says. "That's a substantial increase from the previous years."
Comment on the proposed rule
CMS will accept comments on the proposed rule until June 25 and will respond to all comments in a final rule to be issued by August 1, 2012. Facilities can download a display copy of the proposed rule here.
The proposed rule will appear in the May 11, 2012 Federal Register.