Health Information Management

News: 2011 IPPS proposed rule released

CDI Strategies, April 29, 2010

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CMS released its fiscal year (FY) 2011 Inpatient Prospective Payment System (IPPS) proposed rule on Monday, April 19. The rule includes a handful of proposed changes of relevance to CDI specialists, including the following :

  • A documentation and coding adjustment (DCA) of 2.9%
  • Expansion of quality measures
  • MS-DRG revisions
But the biggest proposed change for CDI specialists is the impact on CMI related to a downgrade of acute renal failure from an MCC to a CC, says Heather Taillon, RHIA, manager of coding compliance at St. Francis Hospital in Beech Grove, IN. 
A request for reclassification of diagnosis code 584.9 (Acute renal failure, unspecified) prompted the change, according to p. 212 of the proposed rule. Facilities use the code to capture a wide range of conditions, from renal failure “caused by mild dehydration with only minor laboratory abnormalities all the way through severe renal failure that requires dialysis,” the proposed rule cites one commenter as stating.
Furthermore, the Coding Clinic for ICD-9-CM editorial advisory board receives a number of clarification requests regarding the code, and according to the proposed rule, coders have seen an increase in the use of acute renal failure over acute renal insufficiency.
That’s a problem many CDI professionals experience as they struggle to achieve greater specificity of, and determine when to query for acute renal failure and chronic kidney disease (Editor’s note: Read Robert S. Gold, MD’s article Tips to avoid adding insult to ‘injury’ documentation in the CDI Journal  and examine sample query forms and physician education in the ACDIS Forms & Tools Library.)
“When acute renal insufficiency is documented, the ICD-9-CM index directs the use of code 593.9 (Unspecified disorder of kidney and CMS-1498-P 213 ureter). Diagnosis code 593.9 includes acute renal insufficiency and is classified as a non-CC,” the proposed rule states. “The problem is further compounded by the fact that there is no consistent convention among clinicians for documenting acute renal insufficiency versus acute renal failure.”
Readers can offer their opinion about the proposed change of acute renal failure, unspecified from a MCC to a CC in the ACDIS Weekly Poll. So far 58% of respondents have voted that the change is unfair and 18% thus far say they plan to comment to CMS against the change.
Learn more about the implications of the documentation and coding adjustment (DCA), a proposal that would ultimately reduce the expected total hospital reimbursement by 0.1%—or $142 million—for total payments of operating expenses, on the ACDIS Blog.
For a complete overview of the 2011 IPPS proposed rule please view this special report released last week.

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