The Centers for Medicare & Medicaid Services (CMS) released an update to the Coronavirus Aid, Relief, and Economic Security (CARES) Act, which was published on April 15. This update applies to Inpatient Prospective Payment System (IPPS) facilities, Long-Term Care Hospitals (LTCHs), and Inpatient Rehabilitation Facilities (IRFs). The provisions are found in sections 3710 and 3711 of the CARES Act.
For IPPS, the relative weight of the Medicare-Severity Diagnosis Related Group (MS-DRG) will be increased by 20 percent for cases that have been assigned to the following:
- B97.29 (Other coronavirus as the cause of diseases classified elsewhere) for discharges occurring Jan. 27 through March 31, 2020, or
- U07.1 (COVID-19) for discharges April 1, 2020 through the duration of the public health emergency.
For IRFs, section 3711(a) states that the requirement of 15 hours of therapy per week is waived. This waiver supersedes CMS-1744-IFC, which was an interim rule for COVID-19 response.
For LTCHs, the discharge payment percentage (DPP) is being required to be at least 50 percent during the COVID-19 public health emergency. All admissions during the public health emergency will be counted as the discharge paid at the LTCH standard federal rate, effective for admission dates occurring on or after Jan. 27, 2020.
The adjustment in reimbursement is one reason that facilities should hold their cases that are tested for COVID-19 until the test results are known. By holding the cases, the COVID-19 code can be assigned for all positive cases, based on the updated Official Coding and Reporting Guidelines for COVID-19. Given the reimbursement adjustment, facilities may want to review cases prior to April 1, 2020 to validate that COVID-19 positive test results are accurately assigned with B97.29.
There are concerns about COVID-19 data accuracy; see the article in Perspectives of the Journal of the American Health Information Management Association (AHIMA) that discusses the quality of health data. There are concerns that the first case was diagnosed in Jan. 21, 2020, but coding guidance did not appear until late February. The coding guideline update was followed by the release of U07.1, which was specific for COVID-19 disease. More guidance was released in March. Are we confident that all COVID-19 cases will be identified? It is the responsibility of health information management professionals to ensure that administrative data is accurate.
COVID-19 may be a principal or secondary diagnosis. The definition of principal diagnosis must be applied to inpatient claims. The coding instructions in ICD-10-CM must be followed as well. The updated guidelines discuss the sequencing of COVID-19 and sepsis. Remember that obstetric cases will be different, because the obstetric diagnosis will precede the COVID-19 code. The same would be true for newborns who are born with COVID-19: the newborn code will supersede the COVID-19 code.
It is a new world, and it is important to ensure that data is accurate, and that COVID-19 is coded accurately. Your efforts will pay off!
Programming Note: This to Laurie Johnson’s live reporting every Tuesday on Talk Ten Tuesday, 10-10:30 a.m. EST.
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For all things that are related to COVID-19, you can use this URL: https://www.cms.gov/About-CMS/Agency-Information/Emergency/EPRO/Current-Emergencies/Current-Emergencies-page. This page contains coding advice, updates to regulations, and pricing information.