Tuesday, April 10, 2012

ICD-10 and Medical Device Companies - By Machelle Morningstar,CPC, CPC-H, CEMC, COSC, PCS


International Classification of Diseases, 10th Revision (ICD-10) is right around the corner, at about 18 months out, to implementation on October 1, 2013. With this in mind, it is important for medical device companies to be thinking ahead.  Companies need to be considering such issues as whether their current coding guidance anticipates ICD-10 codes, both PCS (for procedures), as well as CM (for diagnoses).  Are there actual ICD-10-PCS codes that describe their technologies, in detail, or just a basic generic-type device qualifier for their product(s)?  Another issue to consider is physician documentation, does it answer the questions needed for complete PCS or CM coding, in that do physicians know the additional information needed to provide a complete and accurate code in ICD-10?  These issues will be addresses below, with some suggestions for medical device companies. For the purpose of this eblast, focus will be on PCS only. This is not just a “coders only” issue, but it belongs to all entities that have a hand in coding and reimbursement guidance.

Let’s begin with a basic overview of ICD-10-PCS (PSC). PCS is replacing volume 3 of the ICD-9 book, the section that describes hospital inpatient procedures.  The World Health Organization (WHO) is responsible for maintaining the CM portion of ICD-9 and ICD-10.  The WHO has nothing to do with inpatient procedures, or volume 3 of ICD-9. The United States is the only country that will be using PCS and we use PCS for reimbursement purposes, as well as for statistical reporting.  ICD-9, Volume 3, is currently maintained by CMS via the Coordination and Maintenance Meetings that are held twice yearly.  CMS funded a project, and with the 3M Company, created the ICD-10-PCS system.  This new system has four major attributes[1].

1.      Completeness – There should be a unique code for all substantially different procedures.  In Volume 3 of ICD-9-CM, procedures on different body parts, with different approaches, or of different types are sometimes assigned to the same code.
2.      Expandability – As new procedures are developed, the structure of ICD-10-PCS should allow them to be easily incorporated as unique codes.
3.      Multiaxial – ICD-10-PCS codes should consist of independent characters, with each individual axis retaining its meaning across the broad ranges of codes to the extent possible.
4.      Standard Terminology – ICD-10-PCS should include definitions of the terminology used.  While the meaning of specific words varies in common usage, ICD-10-PCS should not include multiple meanings for the same term, and each term must be assigned a specific meaning.

General differences include limited use of “Not Elsewhere Classified” (NEC), “Not Otherwise Specified” (NOS), and Diagnoses are not included with the procedures codes using PCS.  As there are very specific “Value” choices for each code section, there should be very minimal need for NEC or NOS in the future. 



PCS Code Structure consists of seven “Sections” and each Section has specific “Values” to make up each seven alphanumeric code.  Each Section contains up to 34 possible values, and uses the numbers 0-9 and the letters A-H, J-N and P-Z.  The letters “I” and “O” are not used in PCS so as not to confuse them with the numbers “1” and “0”.  The seven characters for Medical and Surgical looks like this:

Section
Body System
Root Operation
Body Part
Approach
Device
Qualifier

A typical code would look like 0BB20ZZ, meaning Medical/Surgical (0), Respiratory System (B), Excision (B) Carina (2), Open (0), No Device (Z) and No Qualifier (Z).  So even though there is no device or qualifier, you would use “Z” to indicate such, so that you have a complete 7 alphanumeric code.  The seven characters are set up in “Tables” and a table has the first three characters, one under the other, at the top of the table, with “Rows” of “values” underneath.  You find the purpose of your procedure in the Medical and Surgical Section, for example – “Insertion” and you know your procedure is on the lumbar spine – which is “Lower Bones,” so you would go to Table “0QH” and then across the Row for “004Z” to complete your code (0QH004Z) for insertion of internal fixation device of the lumbar spine.

It is important to note, devices are only coded when they are left in the body.  Bio-absorbable screws (while they are left in the body) are not coded as a device since they do absorb and are replaced by bone.

There are 31 official Root Operations in the Medical and Surgical Section, with some of these being using in other sections, and some sections have their own section-specific root operations.  Obstetrics uses 10 of the original root operations, as well as two specific only to Obstetrics.  Values for the Body Systems are the same throughout the Medical and Surgical Section.  Approach has seven values and these also are consistent throughout the book.  For more information on the PCS structures, go to www.cms.gov.

How can Medical Device and/or Biologics Companies help with ICD-10-PCS coding?  While in no way trying to influence sales of company products, sales staff and other professionals can use such tools as reimbursement guides, coding call centers, and general education to assist physicians with documentations needs. 

As part of your coding guidance hand-outs, you may want to include a list of Root Operations and Approaches, or better yet, have a small laminated card to give the providers, that allows them to keep it in their pocket.  It is important for physicians to provide accurate, as well as the correct details, for coding professionals to be able to assign the most complete code.  Physicians being aware of the Root Operation definition can greatly assist the coder in what the purpose of the procedure is.  For example, Excision and Resection are two root operations that have clear definitions.  Excision is basically when you take out a portion of a body part, while Resection is when you take out the entire body part.  Physicians, and other medical professionals, often use these words interchangeably.  Coders will need to see a clear picture of what the procedure encompassed.  If the provider states “excision” of the entire kidney, the coder will see that this is actually “resection.”  Unlike in the past, coders are actually able to assume some interpretation, but it still needs to be clearly stated what service or procedure is done.

Another way companies can assist the physicians, is to know what their particular device is called in the PCS guidelines and/or definitions list.  An example may be to state “Coflex, interspinous process device” when documenting. This tells the name of the product, as well as the type of product being use.  While this may not seem like a big deal, coders often may be confused with new technologies when they are first used.  CMS is creating a reference guide with these types of definitions, but it is not currently a very extensive list, and may take quite a while until every device is cross referenced.

In summary, Medical Device Companies can assist their provider customers by encouraging documentation that meets the needs of the physicians procedure, as well as makes is clear for coding.  This will in the long run, assist both the physicians and the facilities with their revenue cycle (which is a good thing) and provide for more accurate data for tracking and statistical purposes.  And last, physicians do not want to be queried by coders for amended documentation when the record lacks information needed, much less be queried many, many times at the onset of ICD-10.  Knowing your products and procedures and how it fits into the ICD-10-PCS world, can be of great benefit to your physician and facility customers.    





[1] CMS 2011b

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