by Lynn Kuehn, MS, RHIA, CCS-P, FAHIMA
The FY 2022 changes to Guideline B4.1c make me extremely concerned about data collection for coding of vascular procedures.
Since its addition to the Guidelines for FY 2018, Guideline B4.1c has read
- “If a procedure is performed on a continuous section of a tubular body part, code the body part value corresponding to the furthest anatomical site from the point of entry.”
For FY 2022, the guideline is radically changed. Guideline B4.1c will read
- “If a procedure is performed on a continuous section of a tubular body part, code the body part value corresponding to the anatomically most proximal (closest to the heart) portion of the tubular body part.”
These thirteen words change everything we understand about vascular procedure coding in ICD-10-PCS and will severely hamper data collection.
Take the example of a vascular procedure in the lower extremities. When a clot extends all the way from the common iliac down the leg through the femoral, popliteal, anterior tibial, and into the arcuate artery of the foot, only the extirpation from the common iliac artery will be coded. The objective of the procedure, clearing the clot or dilating the vessel all the way to the end of the continuous section, will no longer be captured.
While we don’t know why the Cooperating Parties made this change, I have two theories.
Perhaps the guideline change is related to reimbursement. It may be felt that the level of effort to accurately code these more extensive vascular procedures is not justified because it does not ultimately affect reimbursement. There are only a limited number of DRGs now for vascular procedures. Whether the procedure ends at the carotid artery or snakes all the way to the middle cerebral artery the DRG is the same.
I had always hoped that better data would allow a refinement of the payments for more complex vascular procedures. Data is the key to justifying any changes to the DRG that would more accurately reflect the utilization of facility resources needed for the more extensive procedure. If we are not capturing the detailed data with our ICD-10-PCS code, we cannot make the case.
Perhaps the Cooperating Parties felt that the previous guideline was too difficult for coders to accurately apply. In FY 2021, a coder needed to interpret sometimes cryptic procedure notes and trace the progress of the procedure from the point of entry through all the vessels to the furthest anatomical site. In FY 2022, a coder will need to identify only the most proximal point nearest to the heart. Done. Next chart.
But training is the solution, not radically changing the guideline. Accurate and complete coding of vascular procedures is not asking too much of a skilled coder. Knowledge of anatomical structures is foundational to the work of coders. Understanding complex and lengthy surgical procedures and turning the story of the procedure into correct ICD-10-PCS codes is what coders do.
What is profoundly disappointing is the Cooperating Parties’ apparent willingness to give up on the promise of ICD-10-PCS: detailed and specific data on inpatient procedures performed in US hospitals. This change to the guideline results in even less specific coded data than we had in ICD-9.
Data is everything. It justifies reimbursement; it determines efficacy of procedures; it is the source of evidence-based medicine. Don’t we want and need this data any longer?
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