Settling on a Secondary Diagnosis: Part I

EDITOR’S NOTE: This is the first in a two-part series on the subject of secondary diagnosis.

I have read a lot of literature regarding secondary diagnoses, and the typical dogma is that a condition must meet one of the following criteria to be considered codable, according to the ICD-10-CM Official Guidelines for Coding and Reporting, for the 2017 fiscal year:

For reporting purposes, the definition for “other diagnoses” is interpreted as additional conditions that affect patient care in terms of requiring:
 
1.   Clinical evaluation or
2.   Therapeutic treatment or
3.   Diagnostic studies or
4.   An extended length of stay or
5.   Increased nursing care and/or monitoring

 
Please note that it reads “is interpreted,” and does not express an imperative.

This list is actually commentary on the Uniform Hospital Discharge Data Set (UHDDS) intended to standardize hospital data reporting. Those data elements and definitions are found in the July 31, 1985 Federal Register (Vol. 50, No, 147), pp. 31038-40 (Federal Register Vol 50, No 147). The original instructions state that “other diagnoses are designated and defined as: all conditions that coexist at the time of admission, that develop subsequently, or that affect the treatment received and/or length of stay. Diagnoses … related to an earlier episode which have no bearing on the current hospital stay are to be excluded.”

The phrase that led to the criteria listed above is “…that develop subsequently, or that affect the treatment received and/or length of stay.” If a problem or complication arises during the hospitalization, there is invariably some work-up, treatment, or increase in the length of stay, thus meaning the criteria are met.

My opinion is that the intent of these instructions was primarily to prevent coders from picking up diagnoses from prior encounters that have no relevance to the current admission (…diagnoses … related to an earlier episode which have no bearing on the current hospital stay are to be excluded”). If a condition has no bearing on the current encounter, it should not enter into the calculation of severity or complexity of illness.

What causes a clinician to record a diagnosis that is not relevant? Discounting documentation of extraneous diagnoses for nefarious purposes of fraud, there are probably three main reasons.

The biggest contributor likely stems from the electronic medical record being able to propagate diagnoses in perpetuity, with providers not cultivating the problem list, thereby carelessly importing problem list diagnoses into the assessment and plan section. This can be compounded by the fact that many providers do not understand the difference between “history of” and a chronic condition.

Often, the problem list diagnoses and corresponding ICD-10-CM codes are selected by the healthcare provider (HCP), not a certified, trained coder. They frequently select convenient, albeit erroneous, codes. They type in “P-U-L-M-O-N-A-R-Y E-M-”, and then the electronic medical record (EMR) helpfully suggests I26.99 with the verbiage of “Pulmonary embolism.” Click! The HCP is satisfied and moves on. HCPs don’t know the difference between I26.99, Other pulmonary embolism without acute cor pulmonale; I27.82, Chronic pulmonary embolism; or Z86.711, Personal history of pulmonary embolism. Choosing a suboptimal code for your professional superbill is one thing; inserting it into a problem list that is never revised or edited, and that follows the patient forever, is another. Full disclosure: my personal belief is that doctors should concern themselves with providing excellent quality medical care and leave coding to the professionals, but that is a topic for a different day.

The final factor is providers that fail to take the time to actually think about the circumstances of each encounter and which conditions and diagnoses matter today. HCPs are being asked to increase productivity and use the EMR to record it, so copying and pasting is much more efficient than typing in a new assessment and plan each day. The only way to address this is to (shameless insertion of my personal motto) put “mentation” back into documentation.

So this explains how we end up with “left knee bursitis” from seven years ago in today’s documentation of an encounter for acute exacerbation of systolic congestive heart failure, and how coders must analyze whether each diagnosis is really a codable, current, clinically valid condition (or whether it is not relevant).

Next week, I will address an issue I believe derives from the misinterpretation of the UHDDS, and may be even more important. I will also try to give you strategies to approach these conundrums.

Facebook
Twitter
LinkedIn

Erica Remer, MD, FACEP, CCDS, ACPA-C

Erica Remer, MD, FACEP, CCDS, ACPA-C has a unique perspective as a practicing emergency physician for 25 years, with extensive coding, CDI, and ICD-10 expertise. As physician advisor for University Hospitals Health System in Cleveland, Ohio for four years, she trained 2,700 providers in ICD-10, closed hundreds of queries, fought numerous DRG clinical determination and medical necessity denials, and educated CDI specialists and healthcare providers with engaging, case-based presentations. She transitioned to independent consulting in July 2016. Dr. Remer is a member of the ICD10monitor editorial board and is the co-host on the popular Talk Ten Tuesdays weekly, live Internet radio broadcasts.

Related Stories

Leave a Reply

Please log in to your account to comment on this article.

Featured Webcasts

Mastering Principal Diagnosis: Coding Precision, Medical Necessity, and Quality Impact

Mastering Principal Diagnosis: Coding Precision, Medical Necessity, and Quality Impact

Accurately determining the principal diagnosis is critical for compliant billing, appropriate reimbursement, and valid quality reporting — yet it remains one of the most subjective and error-prone areas in inpatient coding. In this expert-led session, Cheryl Ericson, RN, MS, CCDS, CDIP, demystifies the complexities of principal diagnosis assignment, bridging the gap between coding rules and clinical reality. Learn how to strengthen your organization’s coding accuracy, reduce denials, and ensure your documentation supports true medical necessity.

December 3, 2025

Proactive Denial Management: Data-Driven Strategies to Prevent Revenue Loss

Denials continue to delay reimbursement, increase administrative burden, and threaten financial stability across healthcare organizations. This essential webcast tackles the root causes—rising payer scrutiny, fragmented workflows, inconsistent documentation, and underused analytics—and offers proven, data-driven strategies to prevent and overturn denials. Attendees will gain practical tools to strengthen documentation and coding accuracy, engage clinicians effectively, and leverage predictive analytics and AI to identify risks before they impact revenue. Through real-world case examples and actionable guidance, this session empowers coding, CDI, and revenue cycle professionals to shift from reactive appeals to proactive denial prevention and revenue protection.

November 19, 2025
Sepsis: Bridging the Clinical Documentation and Coding Gap to Reduce Denials

Sepsis: Bridging the Clinical Documentation and Coding Gap to Reduce Denials

Sepsis remains one of the most frequently denied and contested diagnoses, creating costly revenue loss and compliance risks. In this webcast, Angela Comfort, DBA, MBA, RHIA, CDIP, CCS, CCS-P, provides practical, real-world strategies to align documentation with coding guidelines, reconcile Sepsis-2 and Sepsis-3 definitions, and apply compliant queries. You’ll learn how to identify and address documentation gaps, strengthen provider engagement, and defend diagnoses against payer scrutiny—equipping you to protect reimbursement, improve SOI/ROM capture, and reduce audit vulnerability in this high-risk area.

September 24, 2025

Trending News

Featured Webcasts

Surviving Federal Audits for Inpatient Rehab Facility Services

Surviving Federal Audits for Inpatient Rehab Facility Services

Federal auditors are zeroing in on Inpatient Rehabilitation Facility (IRF) and hospital rehab unit services, with OIG and CERT audits leading to millions in penalties—often due to documentation and administrative errors, not quality of care. Join compliance expert Michael Calahan, PA, MBA, to learn the five clinical “pillars” of IRF-PPS admissions, key documentation requirements, and real-life case lessons to help protect your revenue.

November 13, 2025
E/M Services Under Intensive Federal Scrutiny: Navigating Split/Shared, Incident-to & Critical Care Compliance in 2025-2026

E/M Services Under Intensive Federal Scrutiny: Navigating Split/Shared, Incident-to & Critical Care Compliance in 2025-2026

During this essential RACmonitor webcast Michael Calahan, PA, MBA Certified Compliance Officer, will clarify the rules, dispel common misconceptions, and equip you with practical strategies to code, document, and bill high-risk split/shared, incident-to & critical care E/M services with confidence. Don’t let audit risks or revenue losses catch your organization off guard — learn exactly what federal auditors are looking for and how to ensure your documentation and reporting stand up to scrutiny.

August 26, 2025

Trending News

Prepare for the 2025 CMS IPPS Final Rule with ICD10monitor’s IPPSPalooza! Click HERE to learn more

Get 15% OFF on all educational webcasts at ICD10monitor with code JULYFOURTH24 until July 4, 2024—start learning today!

CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 2 with code CYBER24