Hospice ICD-10 Transition Notes: Important Reminder on Manifestation, Unspecified Codes
September 22, 2015 02:36 PM
With October 1 and the transition to ICD-10-CM coding right around the corner, we remind hospices that there remains a prohibition on use of certain diagnosis codes as the principal diagnosis on hospice claims, and we also remind hospices that failure to transition to ICD-10 CM codes at the appropriate time may impact the processing of Notices of Election (NOEs) and Notices of Termination/Revocation (NOTRs). Effective October 1, 2014, hospices are requires to submit NOEs and NOTRs within 5 days following the start of care, and have those notices accepted by the Medicare Administrative Contractor (MAC). The NOE requires the principal diagnosis code. Any NOEs submitted with dates of service on or after October 1, 2015 with an ICD-9 diagnosis code will be returned to provider (RTP’d). This may result in an untimely NOE and loss of some days of payment for the hospice. Additionally, any NOTR submitted with an ICD-9 code with dates of service on or after October 1, 2015 will also be RTP’d.
NAHC has been communicating with the Centers for Medicare & Medicaid Services (CMS) regarding whether a principal diagnosis code is required on the NOTR. The CMS Claims Processing Manual, Chapter 11 indicates it is required; however, we understand that some of the Medicare Administrative Contractors (MACs) are processing NOTRs without a principal diagnosis code. We further understand from CMS that clarification of this issue is forthcoming. We will notify you when that clarification is available.
Relative to codes that may not be used as principal diagnosis codes, Attachment A from Change Request (CR) 8877 is a list of some of the diagnosis codes in ICD-10 that cannot be used as principal diagnosis codes. In addition to these codes, any manifestation code in ICD-10 cannot be used as the principal diagnosis code on hospice claims. Change Request (CR) 9290 updated the Integrated/Outpatient Code Editor (I/OCE) with a list of manifestation diagnosis codes that would also be unacceptable as a principal diagnosis code for hospice claims. In addition to this list from CR 9290, other manifestation codes can also be found listed on pages 134-137 of the ICD-10 Dx Edit Code List (v15.0 ICD-10 Pilot),
Following is the list of ICD-10 code(s) that were added to the list of manifestation diagnoses as part of CR 9290 effective 10/01/2015:
SPECIAL NOTE: CMS currently does not have an edit that compares the principal diagnosis on the NOE with the principal diagnosis on a subsequent hospice claim.
Some hospices have been making corrections to the NOE when the principal diagnosis code on the claim does not match that of the NOE. The correction to the NOE in this case requires backing the NOE out of the system, which in almost all cases results in an NOE that was not filed timely. This equates to a loss of revenue for the hospice. Therefore, we wish to reiterate for hospices that the only time a correction needs to be made to the NOE is when the information on the NOE is actually wrong at the time of the submission. If the principal diagnosis code identified at admission, and put on the NOE, is later changed but was accurate at the time of admission (based upon information that was available at the time), it is not an error on the NOE and does not need to be corrected.