This web-exclusive Journal column highlights public policy initiatives at the federal- and state-level that impact the HIM profession, including news on AHIMA’s national and affiliated state advocacy initiatives, Congressional updates, news from federal regulatory agencies, public policy updates from state legislatures, and AHIMA’s public policy initiatives with other organizations.
By Sue Bowman, MJ, RHIA, CCS, FAHIMA
The ICD-10 Coordination and Maintenance (C&M) Committee, co-chaired by the Centers for Medicare and Medicaid Services (CMS) and the National Center for Health Statistics/Centers for Disease Control and Prevention, met March 5-6, 2019, to discuss proposals for new or modified ICD-10-CM and ICD-10-PCS codes. All of the ICD-10-PCS code proposals were being considered for October 1, 2019 implementation, whereas the ICD-10-CM code proposals, if approved, would be implemented October 1, 2020.
Highlights of the ICD-10-PCS code proposals included implantation of the CivaSheet® brachytherapy device, extracorporeal membrane oxygenation for cardiopulmonary support, endovascular arteriovenous fistula creation using magnetic-guided radiofrequency energy and venous embolization, and treatment of unruptured intracranial aneurysm using flow diverter stent. A number of the ICD-10-PCS proposals involved submission of an application for a new technology add-on payment. Administration of this add-on payment requires specific identification of the applicable technology, usually through an ICD-10-PCS code. CivaSheet is an implantable low-dose rate brachytherapy that is used in the treatment of certain localized tumors. It uses a unidirectional source and is applied during the same operative session as a tumor resection. New codes were also proposed for Extracorporeal Membrane Oxygenation (ECMO) in order to differentiate ECMO used for intraprocedural support from that used for life support, as well as to differentiate between peripheral vessel percutaneous and peripheral vessel open cutdown veno-venous and veno-arterial ECMO. A unique code for a type of endovascular arteriovenous fistula that is created using magnetic-guided arterial and venous catheters that use radiofrequency energy was discussed. A new ICD-10-PCS device value to identify a flow diverter stent for the treatment of nonruptured intracranial aneurysm was proposed. The flow diverter device is implanted in the parent blood vessel to divert blood away from the aneurysm.
Several ICD-10-PCS code proposals involved the administration of specific drugs. Although drug administration is not typically coded, ICD-10-PCS codes are needed to identify drugs that are subject to the new technology add-on payment policy, as CMS’ systems are currently not able to use another mechanism, such as the National Drug Code (NDC) to capture this information. New codes were proposed for the administration of ELZONRIS™, Venclexta®, Caplacizumab, CONTEPO®, XOSPATA®, AZEDRA®, Jakafi®, and IMI_REL. ELZONRIS is an antineoplastic drug. Venclexta is used in the treatment of acute myeloid leukemia. Caplacizumab is used to treat adults with acquired thrombotic thrombocytopenic purpura. CONTEPO is an antibiotic designed to treat multi-drug resistant pathogens. XOSPATA is used in the treatment of relapsed or refractory acute myeloid leukemia. AZEDRA is used to treat certain types of pheochromocytoma or paraganglioma. Jakafi, while used to treat other medical conditions in the past, is a new treatment for acute graft versus host disease.
A number of new ICD-10-CM codes were proposed to identify social determinants of health. While ICD-10-CM already includes some codes for social determinants of health, the proposal would expand these codes and provide more detail. For example, codes pertaining to problems related to employment would be expanded to identify that the individual is unemployed and seeking work, unemployed but not seeking work, employed part-time or temporarily, or employed full-time. Problems related to low income would be expanded to further specify that the individual is unable to pay for prescriptions, utilities, medical care, transportation, phone, adequate clothing, or child care. United Healthcare requested further granularity in order to appropriately capture and analyze social determinants of health data to improve outcomes for both consumers and populations. For example, addressing an inability to pay for prescriptions requires a different action, using different resources, than addressing an inability to pay for transportation. The code expansion requester indicated that the proposal would better capture social issues and barrier situations to assist providers and consumers in obtaining routine care, medications, and preventive services that are not captured today. A related proposal was a request from the Blue Cross Blue Shield of Vermont and the Yale School of Nursing for new codes pertaining to food insecurity. This code proposal involved new codes that would distinguish lack of food, food insecurity, and lack of safe drinking water. A new code was also proposed for noncompliance with dietary regimen due to financial hardship.
ICD-10-CM code proposals included a request for codes for substance abuse with withdrawal. Clinically, it was originally thought that withdrawal only developed in individuals with a diagnosis of substance dependence. However, it is now known that substance withdrawal can occur in clinical situations involving individuals who use substances regularly and then suddenly stop using them, but who do not have a diagnosis of substance dependence.
The United States Lifesaving Association requested unique ICD-10-CM codes that would identify specific natural water settings where drowning and submersion occur, including open sea, oceanfront water, ocean bay, Great Lakes, lake or pond, river or stream, or flooded area. New codes were also proposed for encounter for observation for suspected foreign body ruled out. This situation typically occurs in the pediatric population, whereby a child is thought to have ingested or inserted a foreign body, but testing determines that no foreign body is present.
Code proposals for a number of eosinophilic diseases were discussed, including eosinophilic gastrointestinal diseases, hypereosinophilic syndromes, and pulmonary eosinophilic diseases. In eosinophilic gastritis, elevated levels of eosinophils cause injury and inflammation to the stomach, whereas eosinophilic gastroenteritis involves injury and inflammation to both the stomach and small intestine. Hypereosinophilic syndromes are a clinically and pathogenically heterogeneous group of disorders characterized by elevated blood eosinophil count and eosinophil-mediated end-organ damage. Other eosinophil diseases for which new ICD-10-CM codes were requested are drug rash with eosinophilia and systemic symptoms (DRESS) syndrome and eosinophilic granulomatosis with polyangiitis (EGPA).
The deadline for comments on the ICD-10-PCS proposals is April 5, and for ICD-10-CM proposals the deadline is May 10. June 14 is the deadline for submission of topics for the agenda of the September 10-11 ICD-10 C&M Committee meeting. Comments on ICD-10-PCS proposals or requests for new or revised ICD-10-PCS codes or Index changes should be sent to ICDProcedureCodeRequest@cms.hhs.gov. Comments on ICD-10-CM proposals or requests for new or revised ICD-10-CM codes or Index changes should be sent to firstname.lastname@example.org.
Comments on ICD-10-CM or ICD-10-PCS proposals or suggestions for code changes may also be sent to AHIMA at email@example.com.
Click here for a recording of the March C&M meeting and materials for the ICD-10-PCS portion of the meeting.
Click here for materials for the ICD-10-CM portion of the March C&M meeting.
Sue Bowman (firstname.lastname@example.org) is senior director, coding policy and compliance at AHIMA.