Revenue Cycle

Master wound care coding to prepare for RAC audits

Recovery Auditor Report, May 28, 2009

Coders should arm themselves with as much wound care and coding knowledge as possible to prepare for anticipated RAC audits, says Gloryanne Bryant, BS, RHIA, RHIT, CCS, senior corporate director of coding and HIM compliance at Catholic Healthcare West in San Francisco.
That means understanding the clinical difference between excisional and nonexcisional debridement, knowing what documentation is required to support each procedure, and proactively educating physicians and other staff members who perform these procedures about what they need to document in the medical record.
Bryant also offered a few suggestions on how to prepare for the RACs that may target this area of coding:
  • Reviewing all Coding Clinic guidance dating back to the 1980s. Guidance regarding wound care coding has changed many times since Coding Clinic offered initial advice in 1988. Since then, it has published nine more clarifications. The most recent guidance came in Coding Clinic, in the third and fourth quarters of 2008.
  • Implement standardized processes for documenting debridement. Pay particular attention to excisional debridement, as it typically falls under a higher-paying MS-DRG. During the demonstration project, the RACs focused on insufficient terminology in documentation.
  • Track debridement cases at your facility. Especially focus on cases for which coders assign ICD-9 procedure code 86.22. Bryant said she started doing this in a homegrown spreadsheet within her system and continues to use coding compliance software to track this procedure information.
  • Audit a random sample of patients coded with 86.22. Look for coding errors and fix any inaccurate claims. However, don’t change documentation in a medical record to prove excisional debridement, Bryant said. During a CMS RAC Open Door Forum in 2008, Bryant asked for clarification about how far back hospitals can change medical records. CMS responded that hospitals may amend documentation “in a timely manner,” but did not provide more information. Bryant urged caution here.
  • Suggest the need for a standardized appeal letter. If the RAC claims that documentation in a medical record does not support ICD-9-CM procedure code 86.22, but you believe it does, “go back, look at the policy, look at the documentation, and appeal that case,” Bryant said.
Editor’s note: This tip was excerpted from the article “Understand inpatient wound care coding for RAC audits,” published in the May issue of Briefings on Coding Compliance Strategies. For more information on the audio conference, “ICD-9-CM Procedural Coding for Wound Care and Debridement: Confront Compliance and RAC Challenges,” visit HCMarketplace.

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