Title 42 of the Code of Federal Regulations Part 2 (often referred to as 42 CFR Part 2, or simply “Part 2”) regulates the sharing of substance use disorder (SUD) records. Protecting patients’ confidentiality is of the utmost importance but the outdated nature of Part 2 has created barriers for providing the best care possible to individuals with SUD, often leaving clinicians unaware of risks from multiple drug interactions and co-existing medical problems.
In June, the House of Representatives passed HR 6082, the Overdose Prevention and Patient Safety Act by a vote of 357 to 57. The OPPS Act enables appropriate sharing of substance use disorder records by aligning Part 2 with HIPAA for purposes of treatment, payment, and operations. The bill also includes criminal, civil, and administrative protections for patients during legal proceedings and applies HIPAA penalties to the Part 2 program to ensure that patients can seek treatment without fear their information will be inappropriately shared.
The Senate is putting the finishing touches on its opioid legislation this week. We need you to take action and urge your US Senator to support Part 2 reform as part of the opioid package.
Call your US Senator to ask him or her to support Part 2 reform as part of the opioid package.
AHIMA’s Advocacy Action Center has everything you need to take action.
Your assistance is critical to getting Part 2 reform passed out of the US Senate!
To continue to align with AHIMA’s Strategic Objective, the focus of AzHIMA’s coding roundtable is to provide education to the members to continue to “prepare HIM professionals for the future” (AHIMA). It is the desire of AzHIMA to be a leader in this area. For us to reach this objective, we rely on membership input. We also rely on each other to learn and share ideas. One of the best ways to learn is to talk about what is known, as Benjamin Franklin said, “Tell me and I forget. Teach me and I remember. Involve me and I learn.” Consider becoming involved.
~Crystal Champaigne (firstname.lastname@example.org)
By Pam Hess, MA, RHIA, CCS, CDIP, CPC
AHIMA House of Delegates (HoD) Vote on Standards of Ethical Coding.
This October there was a proposed update to on the Standards of Ethical Coding. This is an important document that governs now medical coding from an ethical perspective. The 47 of the 52 Component State Association (CSA) delegates voted as follows: 150 for, 4 against, 2 abstained.
The updated document itself can be found on AHIMA Engage.
Because this document governs the practice of medical coding for all HIM practitioners, I would advise that each of you review it. Many of our newer HIM practitioners may not be aware of the existence of this document. It is up to us as a professional association member to share the information and make that we are all in compliance. The document explains the “expectations of professional conduct for coding professionals involved in diagnostic and/or procedural coding, data abstraction and related coding and/or data activities.” 1
To provide clarity within the document, the Standards include a list of definitions related to the practice of coding. The body of the document and primary content includes the Standards and Guidelines themselves. There are eleven standards with sub standards within each that explain the actions that a coding professional shall and shall not do:
- “Apply accurate, complete, and consistent coding practices that yield quality data.
- Gather and report all data required for internal and external reporting, in accordance with applicable requirements and data set definitions.
- Assign and report, in any format, only the codes and data that are clearly and consistently supported by health record documentation in accordance with applicable code set and abstraction conventions, and requirements.
- Query and/or consult as needed with the provider for clarification and additional documentation prior to final code assignment in accordance with acceptable healthcare industry practices.
- Refuse to participate in, support or change reported data and/or narrative titles, billing data, clinical documentation practices, or any coding related activities intended to skew or misrepresent data and their meaning that do not comply with requirements.
- Facilitate, advocate, and collaborate with healthcare professionals in the pursuit of accurate, complete and reliable coded data and in situations that support ethical coding practices.
- Advance coding knowledge and practice through continuing education, including but not limited to meeting continuing education requirements.
- Maintain the confidentiality of protected health information in accordance with the Code of Ethics.
- Refuse to participate in the development of coding and coding related technology that is not designed in accordance with requirements.
- Demonstrate behavior that reflects integrity, shows a commitment to ethical and legal coding practices, and fosters trust in professional activities.
- Refuse to participate in and/or conceal unethical coding, data abstraction, query practices, or any inappropriate activities related to coding and address any perceived unethical coding related practices.” 1
Did you know?
Standard #1 requires that managers foster an environment that supports honest coding practices. 1 This means that each manager is responsible to ensure that coders know about the Standards and that an environment is created to allow for expression of concerns if there is a potential violation. This violation could be something as simple as using information from a previous encounter to code from when that is not acceptable per the guidelines. An exception to this might be within the HCC guidelines where CMS specifically allows the inclusion of inpatient, outpatient and professional fee records for HCC assignment where applicable to the current encounter.
Standard #4 requires that coding managers develop query policies within their scope of responsibility to include “Designing and adhering to policies regarding the circumstances when providers should be queried to promote complete and accurate coding and complete documentation, regardless of whether reimbursement will be affected.” 1 This means that queries should be submitted to ensure that the record reflects the actual diagnosis and treatment provided even if it does not result in a change in reimbursement. Standard #4 also speaks to the practice of unnecessary queries such as querying for a gram-negative pneumonia on each pneumonia case. 1
Standard #5 is especially important and it outlines the proper communication between coders or HIM/Coding Managers and the compliance department when there is any misrepresentation of codded data to “inappropriately increase reimbursement, justify medical necessity, improve publicly reported data, or qualify for insurance policy coverage benefits.” 1
These are just a few of the gems you will find in the Standards of Ethical Coding Document. It would be a good idea to go over this document with your coding staff to ensure that they are aware that they are governed by a professional practice outlined by our professional association AHIMA.
Happy reading! And we will see you next time.
Standards of Ethical Coding, December 5, 2016, http://bok.ahima.org/PdfView?oid=301963
Click here to read more
AHIMA is rolling out a new membership model. Learn more about the various membership types AHIMA offers and the costs and benefits associated with them. Instead of a one-size-fits-all approach to membership, each member will be empowered to select the AHIMA content, services, and products they most value.
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By: Deanna Matson, RHIA
HIM Healthcare Consultant
Have you ever sat and wondered how all the events that AzHIMA puts on throughout the year, year after year, get done? Have you ever wondered how the newsletter, the web page, the specialty meetings and the special events take shape? Have you ever thought that maybe, just maybe, you could contribute in some small, special, or significant way? If this sounds like you then now is the time to act.
As Deb Beisel-Denton stated to me recently “people think they have to be great speakers or be an expert on a subject to be involved, that is not true.” What AzHIMA needs most to keep the wheels turning and the education coming is for people to share what they enjoy and what they have a passion for.
This might mean you could write an article of interest for the newsletter, you might like to create puzzles or word games. Perhaps you like to bake and you would be willing to provide baked goods for a Coding Roundtable meeting. Maybe you have a desire to speak at a meeting on a topic of special interest to the membership at large. Or perhaps you have a special interest in helping to plan a meeting or annual event or to assist with the association web presence. No matter what your skill level or area of interest there is a place where you can contribute.
We are always our own worst critics. We often talk ourselves out of offering our services because we feel they have no value. Or we think we are not an “expert”. We do not need to be experts to participate. We just need a desire, a starting point, and willingness coupled with action to participate. We also need the opportunity. AzHIMA can be your opportunity to have your turn.
I encourage you to consider how much value you take away from the AzHIMA web page, publications and web or face-to-face meetings because “someone else” took the time to contribute. These members are not always experts. But they do shine!
Have you had a turn? I encourage you today to take the action needed to begin on your path of contribution. We all have something to contribute which will allow us all to shine!
Lisa Hart, MPA, RHIA
Director of Physician Practice Coding
Banner University Medical Group
When it comes to using offshore resources, there are requirements that are not well known to many HIM professionals regarding the use of offshore contractors for Medicaid, Medicare or Tricare patients, even though the requirements are 8 years old.
The requirements created by the Centers for Medicare Services can be confusing because of the language used that they apply to Medicare Advantage Plans (Part C) and to Medicare Drug Plans (Part D). But if your organization has their own MAO or Drug Plan they know all about it and can be a good resource to help you understand the requirements and the attestation process. Click here to read more.
This an important PowerPoint presentation on External Cause Coding and State Edit Questions.
AzHIMA has arranged with Libman Education to provide their popular “Learn From Lynn Kuehn – ICD-10-PCS Quick Consult” webinar series at a discounted price $59 for the entire series! (normally $275). The series includes the following sections:
Quick Consult 1: Body Parts: What to do when you can’t find them
Quick Consult 2: The Mystery of the Anatomical Regions
Quick Consult 3: Devices: What qualifies?
Quick Consult 4: Devices, Devices, Devices and More Devices
Quick Consult 5: Secrets of Approaches
Quick Consult 6: Supplement: The Misunderstood Root Operation
Quick Consult 7: Revision vs. Remove and Re-Do
Quick Consult 8: Breast Reconstructions: Replacement vs. Transfer
Quick Consult 9: OB Revealed
To place your order, email the information requested below to: email@example.com,
or fax it to (978) 371-2671,
or call (207) 865-1181
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It feels like the last few years we have been living and working toward the start of ICD10. Now, more than three months after go-live how well is everyone doing? From a coder standpoint, it seems that everyone took seriously the studying and training to set themselves up to make a successful transition. The payers were ready to accept the claims from providers and healthcare systems and IT had all our systems ready for the ICD10 codes. All in all, it has been a fairly smooth transition for most. The year delay we experienced from October 2014 to October 2015 allowed coders time to practice, IT had time to work through system issues and create more interfaces and providers had more time to work with CDI staff on documenting specificity.
As we enter 2016, what can we expect to see from ICD10? Now that we have joined the majority of the world healthcare systems on ICD10, the U.S. can begin to compare healthcare statistics in a more meaningful way, accurately compare and measure quality of healthcare across the globe as well as evaluate the outcome of new procedures and capture newly developing conditions that just wasn’t possible with ICD9. Within the United States, we will be better able to measure healthcare services and their outcomes through the specificity of ICD10 codes. The much more detail codes within PCS will help us track new technology used in our surgical arenas. Studying those outcomes will help to improve surgical techniques and spur on more innovative technologies. Research will get a boost from the specificity of codes as clinical outcomes will be more detailed.
It will be interesting to see what 2016 will hold for ICD10. We have been on a partial code freeze since October 2011. There have been limited code updates to capture new technologies and diseases since 2012, but again, that has been very limited. October 1, 2016 will see our first regular code release in five years.
One thing we know for sure, we can count on change being part of our coding lives as usual. And who knows – ICD11 could be just around the corner!
As calendar year 2015 comes to a close and 2016 begins, be sure department leaders continue to assess CDI and coder productivity and proficiency with the new code set. To do this, conduct CDI/coder satisfaction surveys and compare previous assessments, and continue to provide additional educational sessions as needed based on those assessments. If you feel you need more advanced ICD-10 studies, consider joining our new AzHIMA study groups.
Many CDI teams will also be the frontline educators for physicians. The same concepts hold true. Continue to assess physician performance and identify target areas for education. Communicate with physicians about areas they struggle with and identify opportunities for additional education. Use a multi-discipline approach incorporating tips into physician newsletters, presenting targeted education during short PowerPoint presentations, craft tip sheets for top problem areas and develop work study groups.
Any education must incorporate the main rationale for ICD-10-CM/PCS: to ensure the successful capture of additional specificity regarding care and conditions treated in America today. At the most basic level, education should highlight documentation requirements associated with appropriate coding. Lack of specificity affects the entire healthcare process. CDI specialists, in their efforts, have a valuable role to play.
Debra Beisel Denton, RHIA, CCS, CCDS
AzHIMA Coding Roundtable Coordinator
Please visit AzHIMA Coding Roundtable to learn more.
Click on the graphic to download the PDF, provided by the AHIMA CDI Task Force.
We are introducing CDI Chat Topics on the Coding Roundtable page. Please take a moment to check it out here.
We are looking for Clinical Documentation Specialists (CDIP/CCDS) to share other tips for ICD-10 documentation opportunities they are learning with ICD-10-CM/PCS.
Please use the form below to share!
For Immediate Release
October 30, 2015
Contact: CMS Media Relations
(202) 690-6145 | CMS Media Inquiries
CMS Finalizes Hospital Outpatient and Ambulatory Surgical Center Policy and Payment Changes, Including Changes to the Two-Midnight Rule and Quality Reporting for 2016
The Centers for Medicare & Medicaid Services (CMS) released the Calendar Year (CY) 2016 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System policy changes, quality provisions, and payment rates final rule with comment period (OPPS/ASC final rule) [CMS-1633-FC] on October 30, 2015.
The CY 2016 OPPS/ASC final rule updates Medicare payment policies and rates for hospital outpatient departments (HOPDs), ASCs, and partial hospitalization services provided by community mental health centers (CMHCs), and refinements to programs that encourage high-quality care in these outpatient settings. Approximately 4,000 hospitals and 60 CMHCs are paid under the OPPS, while approximately 5,300 ASCs are paid under the ASC payment system. The OPPS provides payment for most HOPD services, including partial hospitalization services furnished by HOPDs and CMHCs. OPPS payment amounts vary according to the Ambulatory Payment Classification (APC) group to which a service or procedure is assigned. The final rule also includes important changes to the Two Midnight Rule effective beginning in CY 2016. See the related fact sheet for detailed information.
Click here to read more: https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2015-Fact-sheets-items/2015-10-30-3.html
Fact Sheet: Two-Midnight Rule
In addition, On October 30, 2015, CMS released updates to the Two-Midnight rule regarding when inpatient admissions are appropriate for payment under Medicare Part A. These changes continue CMS’ long-standing emphasis on the importance of a physician’s medical judgment in meeting the needs of Medicare beneficiaries. These updates were included in the calendar year (CY) 2016 Hospital Outpatient Prospective Payment System (OPPS) final rule.
Click here to read more Two-Midnight Rule fact sheet:
THIS WEEK’S INDUSTRY & AHIMA NEWS
Important Interim Advice from NCHS on Excludes 1 Notes
We have received several questions regarding the interpretation of Excludes1 notes in ICD-10-CM when the conditions are unrelated to one another.
Answer: If the two conditions are not related to one another, it is permissible to report both codes despite the presence of an Excludes1 note. For example, the Excludes1 note at code range R40-R46, states that symptoms and signs constituting part of a pattern of mental disorder (F01-F99) cannot be assigned with the R40-R46 codes. However, if dizziness (R42) is not a component of the mental health condition (e.g., dizziness is unrelated to bipolar disorder), then separate codes may be assigned for both dizziness and bipolar disorder. In another example, code range I60-I69 (Cerebrovascular Diseases) has an Excludes1 note for traumatic intracranial hemorrhage (S06.-). Codes in I60-I69 should not be used for a diagnosis of traumatic intracranial hemorrhage. However, if the patient has both a current traumatic intracranial hemorrhage and sequela from a previous stroke, then it would be appropriate to assign both a code from S06- and I69-.
Announcing ICD-10 Coding Roundtables
Attending coding roundtables is an exciting way for coders and clinical documentation specialists (CDS) to keep up-to-date on coding education and participate in hands-on practice. Coding scenarios with answers will be provided for practice and discussion. These are “working” meetings and coders and CDS should come to the roundtable prepared to code and participate in discussion regarding the coding scenarios (we will have ICD-10 books available but only a limited number so if you have one – please bring it!).
Each coding roundtable will have one facilitator for inpatient scenarios and a facilitator for outpatient scenarios who will present the coding scenario and moderate discussion, drawing out comments and questions, taking notes, and encouraging participation from participants. At the conclusion, the moderator will solicit feedback as to whether the session was useful, how it can be improved, and gather suggestions for future discussion topics.
- Provides on-going face to face coding education and CEUs at a reasonable price
- Improve coding skills through practice and group discussions
- Provide networking opportunities
Please consider volunteering:
- Table Facilitator
- Guest Speaker
- Submitter of Clinical Cases
You can also:
- Submit coding and clinical documentation questions
- Submit challenging ICD-10-CM/PCS coding cases
- Submit CDI documentation questions
- Submit other types of questions related to coded data
Debra Beisel Denton, Chair
Susan Ishikawa, Co-Chair