Health Information Management

News: CMS reports HAC rates, HAC program to come to Medicaid, renewed push for CDI specialist involvement

CDI Strategies, April 14, 2011

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Hospital acquired conditions (HAC): The phrase seems simple enough to understand. These are conditions one acquires while in the hospital, right? Like most phrases included in the healthcare vernacular, however, discussion of HAC contains various levels of detail that can be difficult to understand.

As CMS adds new initiatives to its agenda related to HAC, however, understanding the terminology and investigating the record for evidence of these conditions becomes ever more important, says Glenn Krauss, BBA, RHIA, CCS, CCS-P, CPUR, FCS, PCS, CCDS, C-CDIS, director of Clinical Documentation Improvement Services at YPRO Corporation inIndianapolis, IN.

Medicare plans to incorporate HAC as an integral part of the Hospital Value Based Purchasing Program, according to a CMS proposal published in the Federal Register on January 13, 2011. The move is controversial, Krauss says. Hospitals state that they are already penalized under current CMS policies which limit HAC reimbursement.
The proposed hospital-specific baseline performance measures will be calculated using HAC reportable data beginning on July 1, 2011 and will continue for nine months.Beginning in fiscal year 2015, facilities that fall within the top quartile of U.S. hospitals’ HAC will have their Medicare reimbursement for all discharges reduced by 1%, as warranted under Section 3008 of the Patient Protection and Affordable Act, Krauss explains.
Furthermore, in February, CMS issued a proposed rule for Medicaid that would mimic Medicare’s reimbursement for treatment of HACs. (Read more about the expansion on the HCPro website.) The proposal came on the heels of increased Medicaid scrutiny under the Patient Protection and Affordable Care Act, a proposed expansion of the RAC program to Medicaid, and an extension of the National Correct Coding Initiative (NCCI) edits to Medicaid claims.
Although some states already have Medicaid provisions similar to Medicare HAC, the new rule expands payment reductions nationwide and gives states the flexibility to designate additional conditions for reduced payment.
As of April 1, CMS added eight primary HAC conditions to the Hospital Compare website. The eight elements now included in the report are:
  1. Foreign object retained after surgery
  2. Air embolism
  3. Blood incompatibility
  4. Pressure ulcer stages III and IV
  5. Falls and trauma
  6. Vascular catheter-associated infection
  7. Catheter-associated urinary tract infection
  8. Manifestations of poor glycemic control
CMS has reported hospital quality information for years. Before 2007, however, this information was limited to inpatient “process of care measures,” which demonstrate how well hospitals follow generally recognized patient care protocols. In 2007, CMS began reporting outcomes by showing 30-day mortality rates for inpatient hospital stays related to heart attack and heart failure and other items. In 2008, CMS added 30-day mortality rates for pneumonia-related stays as well as 30-day readmission rates for pneumonia, heart attack, and heart failure, according to an April 6 Medicare Fact Sheet.
By reporting HAC measures CMS hopes to shed light on preventable events. The Office of the Inspector General estimates that 13.5% of hospitalized Medicare beneficiaries experienced adverse events during hospitalization. The incorporation of HAC measures helps CMS provides hospitals with a financial incentive to report the quality of their care, and helps consumers make more informed decisions about their care.
So what do these changes mean for the CDI specialists?
“We should take the initiative to redouble our efforts in securing clear, accurate, and concise clinical documentation for these eight HAC conditions as a means of ensuring that the record contains sufficient clinical information for the coder to accurately assign the appropriate POA indicator,” says Krauss. “There is no room for error in the accurate reporting of POAs.”
As a rule of thumb, if the CDI specialist cannot be 100% certain the coder will come to same conclusion as to whether a condition was POA, then further clinical clarification is essential, and a query to the physician is warranted.
“The accurate reporting of HAC on the Hospital Compare website directly depends on our efforts to secure accurate information in the medical record,” Krauss says.

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