Corporate Compliance

CMS issues guidance on the effect of POA indicators for HACs

Medicare Insider, December 2, 2008

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Editor's Note: Kimberly Anderwood Hoy, director of Medicare and compliance for HCPro, is the author of this week's "Note from the Instructor."
 
CMS issued a Special Edition MLN Matters article last week on the present-on-admission indicator. In the article, there are references for coding guidance in the UB-04 Data Specifications Manual and the ICD-9-CM Official Guidelines for Coding and Reporting. CMS also discussed how each one of the indicators will be treated for payment purposes. If a particular hospital-acquired condition is reported with an “N” (for not present on admission) or a “U” (for “documentation insufficient to determine if the condition was present at the time of admission”), the diagnosis will not be considered a complication or comorbidity (CC) or major CC for the purpose of DRG assignment.
                                                   
Treatment of the “U” as hospital acquired is troublesome because of the difficulty of determining from physician documentation whether a condition was present on admission. However, the new ICD-9-CM guidelines, effective October 1, 2008, provide guidance on querying physicians in these cases. The new guidelines provide that documentation of whether a condition was present on admission may be made after the time of admission. The guidelines also specifically mention that it may be appropriate to query the provider if documentation is unclear at the time of coding.
 
The new guidelines provide the following example: Nursing documentation at the time of admission indicates the presence of a decubitus ulcer; however, physician admission notes do not mention it. The physician should be queried as to whether the decubitus was present on admission.[1] 
 
I encourage everyone to review the new present-on-admission indicator guidelines in the latest version of the ICD-9-CM Official Guidelines for Coding and Reporting, and share them with your clinical documentation improvement teams. 


[1]           Just one other note about decubitus coding: The guidelines also added an instruction that if the physician documents a decubitus, but not the stage, the stage of decubitus may be coded from nursing documentation.
 
 



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