Health Information Management

Q&A: Use of E codes in reporting postoperative complications

CDI Strategies, December 20, 2012

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Q: Can you clarify the requirements surrounding the use of E codes? We have been working on documentation concerns related to patient safety indicator (PSI) 15 and wonder if E codes are really required to be reported or not. Can a facility simply decide to use on not to use them?

A: The use of E codes for adverse effects of drugs in therapeutic use is mandatory throughout the United States, according to AHA’s Coding Clinic for ICD-9-CM (1994, 4th Quarter, pp. 27-28).
The same edition (4th Quarter, pp. 23-24) also states:
 “The use of external cause of injury codes (E codes) to indicate the intent and nature of the cause of the burn(s) is strongly encouraged, and is required in several states and in all accredited trauma centers.”
Faye Brown’s ICD-9-CM Coding Handbook (p. 406) states: “Although reporting external cause is optional unless mandated by state or insurance carrier regulation, healthcare providers are strongly encouraged to report E codes for all initial treatment of injuries.”
The ICD-9-CM Official Guidelines for Coding and Reporting under the introduction to E code use states: “These guidelines are provided for those who are currently collecting E codes in order that there will be standardization in the process. If your institution plans to begin collecting E codes, these guidelines are to be applied.”
Therefore, it appears that although the use of E codes is not widely mandated, it may be required by certain states, insurance companies, trauma registries, or other organizations. Please check the requirement at your individual facility to determine the reporting criteria.
It is also important to note, however, that effective October 1, 2009, CMS requires all providers to submit E codes for three surgical “never events” despite not receiving payments for these procedures. For fiscal year (FY) 2010, the Inpatient Prospective Payment System (IPPS) stated that providers must report the following E codes when filing claims for surgical “never events:”
  • E876.5 – Performance of wrong operation (procedure) on correct patient
  • E876.6 – Performance of operation (procedure) on patient not scheduled for surgery
  • E876.7 – Performance of correct operation (procedure) on wrong side/body part
Please note these E codes would not be the same ones used after an accidental laceration (PSI 15). Typically, codes from category E870 are the E codes used to identify an accidental cut, puncture, perforation, or hemorrhage during medical care.
PSI 15 includes the category E870 codes as well as 998.2 in its definition. Therefore, to qualify for PSI 15, either a code from category E870 or code 998.2 must be present in any secondary diagnosis field. Typically, these codes will be used together. The E870 category codes would not be used without a complication code.
Based on all the above references that are generic for all 50 states, although it may be up to the facility to decide to use E codes (with a few exceptions), there may be other organizations and state-specific requirements that do mandate the use of E codes in your facility.

Editor’s Note: This question was answered by Audrey G. Howard, RHIA, AHIMA-Approved ICD-10-CM/PCS Trainer, is a senior inpatient consultant with 3M Consulting. Contact her at For additional information, order the HCPro Inc., audio on-demand version of Howard’s July 2012 presentation “Impatient Postoperative Complications: Resolve your coding and documentation concerns.”

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