Corporate Compliance

Handling acute renal failure

Compliance Monitor, July 22, 2005

Q: How should we handle Medicare patients diagnosed with acute renal failure who no longer require inpatient care but still require ongoing dialysis treatments?

The physician does not feel that the diagnosis can be changed to chronic renal failure or end-stage renal disease because the patient may regain renal function. Local dialysis providers are not licensed to provide services for acute renal failure diagnoses.

Our hospital is not licensed to do outpatient dialysis. We could admit the patient as an inpatient just for the dialysis and contract with the dialysis clinic to do the dialysis as an inpatient in our facility. However, the patient would not meet inpatient criteria. The patient will require hemodialysis three times a week for an undetermined length of time.

How should this situation be handled from a billing as well as compliance standpoint?

A: The patient should be transferred to an outpatient dialysis facility that can provide outpatient dialysis treatments and bill using the ICD-9 code 584.9 for acute renal failure. A freestanding outpatient dialysis facility should get reimbursed.

A facility can't dialyze the patient as an outpatient in the hospital and receive reimbursement unless it is certified as an outpatient dialysis provider. Even hospitals that have an outpatient dialysis provider number have trouble getting reimbursed when the patient is in acute renal failure because the intermediary believes the treatment was provided in an acute care setting even though it is billed out of their outpatient dialysis unit.

Hospital clients we have worked with that have faced this same issue have had the nephrologist complete Form 2728, Medical Evidence of Chronic Renal Failure, in order to receive reimbursement for the outpatient dialysis treatments performed in their outpatient units and then they submit information to their intermediaries if the patient's renal failure is reversed.

In summary, you need to transfer the patient to a freestanding outpatient dialysis facility. If you can't find a unit that will take the patient because of problems getting reimbursement from an intermediary when patients are "acute renal failure", then you need to ask the physician to complete the 2728.

This question was answered by the consultants at Healthcare Design Specialists.

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