The new debridement DRGs would still be classified as operating room procedures but would result in lower payment, to reflect what CMS says is the lower cost of delivering these services. "We examined MedPAR claims data on all excisional debridement cases and found that these debridement cases use appreciably fewer resources than other cases in their current surgical DRGs," CMS states in the proposed rule.
The change is a reasonable one that may help hospitals that perform many skin graft procedures, whose reimbursement may have been skewed downward by the inclusion of excisional debridement in the same MS-DRGs, says Kennedy. However, because there are no changes to any of the underlying coding or documentation guidance for excisional debridement, coders will still face difficulty differentiating documentation of excision, removal, debridement, and excisional debridement. The fact that CMS maintained excisional debridement as an operating room procedure means that it will continue to generate interest from external reviewers such as the recovery audit contractors (RAC), adds McCall.
New HAC: Contrast-induced acute kidney injury
CMS proposes adding a new condition to the list of HACs subject to reduced payment provisions under the IPPS—contrast-induced acute kidney injury. Although CMS states that there is no unique code that identifies the varying stages of acute kidney injury, the agency would identify it as a subset of discharges with ICD-9-CM diagnosis code 584.9 (acute kidney failure, unspecified), which currently qualifies as a CC. CMS contends that it can accurately identify contrast-induced kidney injury when code 584.9 is listed in combination with specified procedure codes from the 88.xx code series. CMS lists these codes starting on p. 113 of the proposed rule display copy.
"All the more reason that providers must be attentive to the potential release of new acute kidney injury codes by the National Center for Health Statistics in May, what impact they may have in gauging contrast-induced nephropathy, and what impact it may have with the other acute renal failure codes, especially 584.5, acute kidney failure with lesion of tubular necrosis," Kennedy says.