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.
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