January 4, 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 October ICD-9-CM Coordination and Maintenance Committee meeting.
Generally support CMS recommendations, with additional comments
Insertion of Multiple Stents We are concerned about revising the title of code 36.01 since this changes the meaning of the code and affects trend data. We recommend deleting code 36.01 and creating a new code for "percutaneous transluminal coronary angioplasty [PTCA] or coronary atherectomy."
Instructional notes to "code also" the number of vascular stents inserted and number of vessels treated should be added under all of the codes listed in the "code also" notes under proposed new subcategory 00.4 (00.55, 00.61, 00.62, 00.63, 00.64, 00.65, 36.01, 36.06, 36.07, 39.50, 39.90).
To simply the long list of "code also" notes under subcategory 00.4, the notes could be shortened to simply state "code also angioplasty or atherectomy, insertion of stent" and then list all of the applicable codes in parentheses - rather than individually listing each angiplasty and stent insertion code. So, the "code also" note would look like this:
Angioplasty or atherectomy (00.61, 00.62, 36.01, 39.50) Insertion of vascular stent (00.55, 00.63, 00.64, 00.65, 36.06, 36.07, 39.90)
This format would make the "code also" note much easier to read.
The instructions for use of the new codes for number of vessels treated and number of stents inserted should clarify which primary procedures they are intended for use with. For example, is their use intended to be limited to angioplasty procedures? Or can these codes be used with other types of vascular procedures that may involve multiple vessels, such as therapeutic intravascular ultrasound or intravascular brachytherapy? All of the applicable primary procedures should be identified and the "code also" note under subcategory 00.4 should be expanded to include any other types of procedures. "Code also" notes identifying the 00.4 codes should be added under the codes for all applicable primary procedures.
We support the suggestion that a note be added under subcategory 00.4 indicating that one code from 00.41-00.44 and one code from 00.45-00.48 should be assigned. This will help to clarify the proper use of these codes.
All instructional notes that reference codes 36.01, 36.02, and 36.05 will need to be revised. For example, there is a note under code 92.27 referencing code 36.02.
The word "adjunct" instead of "other" in the title of subcategory 00.4 would be preferable, since this description would more clearly indicate that the codes in this subcategory must be assigned with other procedure codes.
We do not believe it is necessary to add codes for insertion of bifurcated stents at this time, since there are none currently on the market.
Revision Total Hip and Knee Replacement Our comments on this proposal refer to the draft dated December 1, not the proposal presented at the Coordination and Maintenance Committee meeting.
Notes under proposed subcategory 00.8 and codes 00.81, 00.82, and 00.83 refer to code 81.55 for a total knee revision. However, it appears that code 00.80 is the correct code for a total revision and code 81.55 is for an unspecified revision.
There is a note under code 00.80 indicating that this code includes revision of total knee replacement, NOS. However, code 81.55, not 00.80, is the correct code for revision of knee replacement NOS.
The description of subcategory 84.5 needs to be revised to cover proposed code 84.57. Currently, the description of this subcategory includes only "implantation," not "removal," of musculoskeletal devices and substances.
Cardiac Support Device The Excludes note for "other operations on heart and pericardium (37.99)" under the proposed new code should be deleted. This code is a broad "not elsewhere classified" code that covers many procedures performed on the heart that are completely unrelated to the cardiac support device.
Support CMS recommendations without additional comments
Revision or Relocation of Defibrillator Pocket AHIMA supports the proposal to revise the description of code 37.79 so that it includes revision or relocation of a subcutaneous pocket for any type of cardiac device. This approach is preferable to creating a separate code for revision or relocation of a cardiac defibrillator subcutaneous pocket.
Do not support code proposal
Insertion of Rechargeable Neurostimulator Pulse Generator Since the procedure for inserting a rechargeable neurostimulator pulse generator is the same as for inserting a non-rechargeable device, we do not recommend that new codes be created to differentiate rechargeable from non-rechargeable devices. ICD-9-CM is intended to capture differences in procedures, not differences in types of devices.
Infusion of Liquid Radioisotope This topic needs to be discussed further (at a future Coordination and Maintenance Committee meeting) before implementing new code(s). Code 92.20 seems to adequately capture the actual infusion of the radioisotope. The components of the procedure for which new codes appear to be needed are implantation of the catheter, removal of the radioisotope, and removal of the catheter. A better understanding of the steps of the procedure, and when those different steps occur, would help to achieve consensus on how many codes, and for which components of the procedure, are necessary to fully describe this procedure.
We agree with the concerns raised at the Coordination and Maintenance Committee meeting regarding the "code also" note for electrophysiologic studies (EPS) that was proposed under the pacemaker and defibrillator codes. This note would be confusing, and we recommend that EPS be considered an inclusive part of the procedure for insertion of the pacemaker or defibrillator device.
We support the other 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