June 15, 2005
HCPCS National Panel
c/o Centers for Medicare & Medicaid Services
ATTN: Cindy Hake
Mail Stop C5-08-27
7500 Security Boulevard
Baltimore, Maryland 21244
RE: Comments on Requested HCPCS Code Revisions
Dear Ms. Hake:
The American Health Information Management Association (AHIMA) is submitting these comments in response to public requests for revisions to the HCPCS code set. Our comments are limited to the requests for codes for home health services and general recommendations regarding the process of obtaining public input on HCPCS revisions. AHIMA is a not-for-profit professional association representing more than 50,000 health information management (HIM) professionals who work throughout the healthcare industry. AHIMA's HIM professionals are educated, trained, and certified to serve the healthcare industry and the public by managing, analyzing, and utilizing data vital for patient care, while making it accessible to healthcare providers and appropriate researchers when it is needed most.
Consistency in medical coding and the use of medical coding standards in the US is a key issue for AHIMA. As part of this effort, AHIMA is one of the Cooperating Parties, along with CMS, the Department of Health and Human Services' (HHS) National Center for Health Statistics (NCHS), and the American Hospital Association (AHA). The Cooperating Parties oversee correct coding rules associated with the International Classification of Diseases Ninth Revision, Clinical Modification (ICD-9-CM). AHIMA also participates in a variety of coding usage and standardization activities in the US and internationally, including the American Medical Association's (AMA's) Current Procedural Terminology® (CPT®) Editorial Panel.
Home Health Services (HCPCS Requests #05.168 - #05.172)
AHIMA does not support the requests for new HCPCS codes for social work services, occupational therapy, speech language pathology, nursing, and physical therapy provided in the home. The requests would create "per visit" codes for services for which there are already existing codes for 15 minute increments, by the hour, and per diem. There are already duplicative ways to report these services, differentiated only by time increments. AHIMA recommends that a single code be used for each of these services (social work services, occupational therapy, speech language pathology, nursing, and physical therapy) by all payers, with duration or frequency of service captured through other data elements.
AHIMA believes there should not be multiple ways to code the same service in the same healthcare setting. The use of duplicative or overlapping codes is administratively burdensome and can result in coding confusion and errors, compromises of clinical data, and the inability to conduct data analyses across payers.
The goals of the regulations for electronic transactions and code sets promulgated under the Health Insurance Portability and Accountability Act (HIPAA) include administrative simplification and promotion of uniformity and standardization in claims reporting. Creation of duplicative methods of reporting the same service does not support either of these goals. Also, development of a National Health Information Network, a key initiative of President Bush and the Office of the National Coordinator for Health Information Technology, depends on data standardization and comparability in order to achieve information exchange across healthcare organizations. For this to happen, data and data definitions must be standardized and not reflect individual payer requirements.
Expand Public Input Process to Include Temporary HCPCS Codes
AHIMA appreciates the fact that the public process has been expanded beyond DME requests. We recommend that it be expanded even further to allow public input on the temporary codes, such as the "G" codes. We understand that the temporary codes are intended to meet the operational needs of a particular insurer and are implemented more frequently than the January 1 annual update of the permanent HCPCS codes. Therefore, the timing of the temporary codes may not allow them to be discussed at the public meetings along with the public requests for permanent codes. However, we believe that the temporary codes could be posted on the CMS web site prior to implementation and allow at least a short window of opportunity for written public input. The temporary codes have at least the same degree of impact on providers as permanent codes, and perhaps an even greater impact since they can be implemented more frequently.
There have been occasions in the past when we disagreed with CMS' decision to establish a "G" code because we thought it unnecessarily duplicated or overlapped a code contained in the CPT coding system or we felt there were alternative mechanisms for capturing the necessary information that would not result in duplicative reporting methodologies. In these cases, we would have appreciated the opportunity to share our comments with CMS prior to implementation of the temporary code, rather than trying to address problems created by the code after it has been implemented.
As noted in our earlier comments concerning the request for home health codes, the use of duplicative or overlapping codes is administratively burdensome and can result in coding confusion and errors, compromises of clinical data, and the inability to conduct data analyses across payers. Payment systems should accept standard coding practices, rather than requiring coding standards, descriptions, or practices to be adjusted to fit payment policies.
The federal government's goals of electronic health records (EHRs) for all Americans and an interoperable national health information infrastructure require the use of uniform health information standards. Data must be collected and maintained in a standardized format, using uniform definitions, in order to link data within an EHR system or share health information between systems. The lack of standards for health information has been a key barrier to electronic connectivity in healthcare.
Further Questions and Information
Thank you for consideration of our comments. If AHIMA can provide any further information, or if there are any questions or concerns with regard to this letter and its recommendations, please contact me at (312) 233-1115 or firstname.lastname@example.org.
Sue Bowman, RHIA, CCS
Director, Coding Policy and Compliance
cc. Dan Rode, MBA, FHFMA, Vice President, Policy and Government Relations, AHIMA