Although CMS considered the use of E codes to identify contrast-induced acute kidney injury, it scrapped the idea because E codes are not required on IPPS claims.
CMS is also using the proposed rule to lay the foundation for the coming hospital readmission reduction program mandated by PPACA. The agency proposes to include acute myocardial infarction, heart failure, and pneumonia—based on the current inpatient quality reporting measures—as applicable conditions under the readmissions program, starting in FY 2013.
However, this shouldn't stop providers from analyzing a full range of hospital-specific readmissions, says Bryant. "I would recommend that hospitals run some data to look at readmission rates to determine what their top 3–5 readmissions conditions are," she says. "It's clear that readmissions are a topic of concern for the federal government. Even though we in the industry have talked about readmissions for years, this federal mandate means we need to look at it even more closely."
CMS would adopt the National Quality Forum definition of readmission:
...as occurring when a patient is discharged from the applicable hospital to a non-acute setting (for example, home health, skilled nursing, rehabilitation or home) and then is admitted to the same or another acute care hospital within a specified time period from the time of discharge from the index hospitalization.
For the three proposed applicable conditions the specified time period would be 30 days.
Physicians' offices and the three-day payment window
In response to ongoing requests to clarify the applicability of the payment window policy to preadmission nondiagnostic services provided in hospital-owned or hospital-operated physicians' offices or clinics, CMS clarifies in the proposed rule that the three-day payment window policy applies to both preadmission diagnostic and nondiagnostic services furnished to a patient at physician practices that are wholly owned or operated by the admitting hospital.