April 8, 2004
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 April ICD-9-CM Coordination and Maintenance Committee meeting.
Generally support CMS recommendations, with additional comments
Insertion of Left Atrial Appendage Filter System
AHIMA supports the creation of a new code for insertion of left atrial appendage device and we agree with placement of the code in subcategory 37.9, Other operations on heart and pericardium. We agree with CMS that this procedure does not belong in a “repair “ category.
We support the creation of a new code to identify computer-assisted surgery and prefer option 4 as presented at the meeting, which is creation of a single code. We do not believe it is necessary to differentiate computer-assisted surgery by imaging techniques. Option 2, differentiation of computer-assisted surgery by body system, is unnecessary because the code for the primary procedure would identify the body system.
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Insertion of Palatal Implant
AHIMA supports the creation of a new code to identify insertion of a palatal implant used in the treatment of obstructive sleep apnea. Since this procedure is often performed in conjunction with other nasopharyngeal procedures, notes should be added under the new code indicating that both the insertion of the palatal implant and the other procedure should be coded. Under the codes for the procedures that would most commonly be performed in conjunction with a palatal implant, notes should be added indicating that an additional code should be assigned if a palatal implant is inserted. We recommend that the primary nasophayngeal procedure, such as uvulopalatopharyngoplasty, be sequenced before the insertion of the palatal implant.
Internal Limb Lengthening Device
We support the creation of a new code for implantation of internal limb lengthening device. We recommend that just one code be created to encompass all internal limb lengthening devices.
AHIMA supports the creation of a new code for non-drug-eluting carotid artery stent(s). We agree with the suggestion made at the meeting that the description of the new code be broadened to state “precerebral” instead of limiting it only to the carotid artery. We also support the suggestion to create a new code for precerebral or cerebral angioplasty or atherectomy, instead of classifying this procedure to the code for non-coronary angioplasty. Regarding the suggestion made during the meeting that a new code also be created for insertion of a drug-eluting carotid stent, we believe that would only be appropriate if drug-eluting carotid stents are likely to become available in the next few years. Some individuals present at the meeting indicated that they were not aware of any drug-eluting stents in development nor is there as much necessity for them as for coronary artery stents. Therefore, it may not be necessary to create a code for a drug-eluting stent, at least not at this time.
Vertebroplasty and Kyphoplasty
We support the creation of distinct codes for vertebroplasty and kyphoplasty. The note under the proposed new code for kyphoplasty should be revised to clarify that the vertebral height is not usually restored to its original height. The note under this code should also make it abundantly clear that fracture reduction and injection of cement like material into the collapsed vertebral body should not be coded separately.
Percutaneous External Heart Assist Device
We support the creation of a new code for insertion of a percutaneous external heart assist device. However, the code descriptions and notes for the other codes in subcategory 37.6, Implantation of heart assist system, should be revised so there is no overlap with the code or confusion as to the appropriate code. For example, the approach intended for each of these codes should be clearly specified. Code 37.62 includes insertion of heart assist system, not specified as pulsatile, which could include those inserted via both open and percutaneous approaches. Is code 37.65 intended to include all external, pulsatile heart assist systems, regardless of whether they are inserted via an open or percutaneous approach?
Ultrafiltration of Blood for Removal of Excess Fluid
AHIMA recognizes that the ultrafiltration of blood discussed at the meeting is different than the hemodialysis or plasmapheresis currently classified in ICD-9-CM. Therefore, it may make sense to create a unique code. However, this code would need to be carefully constructed, with appropriate index entries and notes under codes 39.95, Hemodialysis, and 99.71, Therapeutic plasmapheresis, in order to clearly differentiate the services from one another.
Injection of Bone Void Filler
AHIMA supports the creation of a single new code for the insertion of bone void filler. We do not think it is necessary to create separate codes to distinguish between different products. Distinctions between different products might be difficult for coding professionals to determine. Therefore, we feel that creating a single code represents the best option. Clarification, through the use of instructional notes and index entries, needs to be provided to indicate when the new code should be reported as an additional code and when it is considered inclusive of another procedure. For example, should this code be assigned with the proposed code for kyphoplasty?
Do not support code proposal
We do not support the creation of a new code for infusion of vasopressor agents. We do not believe it is an appropriate use of ICD-9-CM to capture this level of detail about the administration of medications.
We support the proposed addenda revisions.
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