| April 13, 2005 |
Patricia Brooks, RHIA
Centers for Medicare & Medicaid Services
CMM, HAPG, Division of Acute Care
Mail Stop C4-08-06
7500 Security Boulevard
Baltimore, Maryland 21244-1850
The American Health Information Management Association (AHIMA) welcomes the opportunity to provide comments on the proposed procedure code modifications presented at the March 31st ICD-9-CM Coordination and Maintenance Committee (C&M) meeting.
Do not support code proposal
Hip Replacement Bearing Surfaces
AHIMA does not support the creation of new codes to identify the types of bearing surfaces used in hip replacement prostheses. ICD-9-CM is intended to describe different types of procedures, not the materials used in prostheses or devices. Given the growing failure of ICD-9-CM to keep pace with medical and technological advances, and the fact that replacement of ICD-9-CM with ICD-10-PCS has been delayed, we feel that the remaining available codes should be saved for use in identifying new procedures or procedural approaches. If details concerning the material used in prostheses are important for evaluating patient outcomes and quality of care, they should be captured via a different mechanism than ICD-9-CM, such as HCPCS level II codes or a device terminology. We are also concerned that the type of bearing surface will not typically be documented in patients' medical records, resulting in significant underuse of the proposed codes.
External Fracture Fixation Devices
We also do not support the creation of new codes for different types of external fixation devices, for the same reasons as cited for hip replacement bearing surfaces. Information concerning the type of external fixation device employed may not be documented in the medical record. We are also concerned with the large number of new codes required by this proposal. Without an implementation date for ICD-10-PCS in sight, ICD-9-CM may need to continue to be used indefinitely, and, therefore, careful consideration must be given to the best use of the rapidly disappearing open codes.
If new codes to identify different types of external fixation systems are created, we would prefer that just two new codes be created in the 84.7 or 84.8 subcategories. The anatomical site would be captured by the diagnosis code, and so it is not necessary to create external fixation device codes for each anatomical site.
Radiofrequency Ablation of (Chronic) Total Artery Occlusion
AHIMA does not feel it is necessary to create a unique code for identification of the circumstance when a chronic total occlusion must be carried out along with an angioplasty and stent placement. Crossing a chronic total occlusion appears to be part of the process for accomplishing the stent placement rather than a distinct procedure that should be separately coded.
Support Code Proposal
360 Degree Spinal Fusion
AHIMA supports option 3 as presented at the C&M meeting. This option involves deletion of code 81.61 and the addition of inclusion terms for PLIF and TLIF under code 81.08 and ALIF under code 81.06. When an interbody fusion device is inserted, code 81.51 would be reported as an additional code. We believe this approach greatly simplifies the coding of these procedures while still capturing the necessary information. Option 2 would result in continued confusion as to the proper code assignment due to unclear medical record documentation as to whether the procedure is an interbody fusion, a fusion of the posterior column by posterior technique, or both.
Infusion of Liquid Radioisotope
We support the creation of new codes to capture the three components of infusion of liquid radioisotope in the treatment of brain cancer (insertion of the catheter, removal of catheter, infusion of radioisotope). This procedure is much more invasive than is reflected by existing codes. We also agree that exclusion terms should be added under codes 92.27 and 92.28.
In light of comments made during the C&M meeting concerning whether or not insertion and removal of drainage tubes could be confused with the new codes, we recommend that appropriate inclusion and exclusion terms be added under the new codes to clarify their intent.
A "code also" note for any concomitant resection should be added under the proposed code for insertion of catheter into cranial cavity
Infusion of Immunosuppressive Antibody Therapy at the Time of Transplantation
AHIMA supports the concept of capturing the infusion of immunosuppressive antibody therapy following organ transplantation. However, if it is possible to receive induction therapy during an encounter subsequent to the encounter for transplantation, the medical record may not clearly indicate whether the patient is receiving induction therapy or maintenance therapy, resulting in confusion as to whether the proposed code should be assigned.
Implantation of Interspinous Process Decompression Device
We support the establishment of a unique code for implantation of interspinous process decompression device and a code for removal of spinal device.
Endovascular Implant in Thoracic Aorta
We also support the creation of a code for endovascular implantation of graft in the thoracic aorta.
Subtalar joint arthroereisis
AHIMA supports the creation of a unique code for subtalar joint arthroereisis. This procedure is clearly distinct from other orthopedic procedures.
Addenda We support the proposed addenda revisions.
We agree with the commenter at the C&M who suggested that "ultrasound" should be added to the title of subcategory 00.2 to clarify that other types of intravascular imaging are not included in this subcategory.
Conclusion The code proposals presented at the C&M meetings emphasize the critical need to replace ICD-9-CM with ICD-10-CM and ICD-10-PCS as soon as possible. ICD-9-CM is not able to meet the healthcare industry's growing demand for increasing levels of coding specificity. In fact, the day is fast approaching when ICD-9-CM will be completely depleted and no new codes can be established, no matter how strong and convincing the case for a new code is. CMS should urge the Secretary to publish a Notice of Proposed Rule-Making for the adoption of ICD-10-CM and ICD-10-PCS as soon as possible in order to ensure the continued ability of our coding systems to meet the government's and industry's demands for high-quality healthcare data. Use of modern, up-to-date coding systems is a key component of the process of transforming our healthcare system.
Thank you for the opportunity to comment on the proposed procedure code revisions. If you have any questions, please feel free to contact me at (312) 233-1115 or firstname.lastname@example.org.
Sue Bowman, RHIA, CCS
Director, Coding Policy and Compliance