Posts Tagged: Connolly Healthcare

Connolly Adds Nine RAC Approved Issues

RAC-LOGO-CGIThe RAC contracted for the southern and southeastern states, Connolly Healthcare, continues to post new automated issues concerning dose-versus-units-billed, further proving that injections and infusions is a major target for RAC review, and a continuing concern for provider reimbursement, especially for physicians and outpatient settings.

The List

Below are the nine new issues, posted earlier this week. Follow the links to each one, in the eduTrax RAC New Issue Database®, which can be seen with simple free registration at myedutrax.com.

Who’s Getting Stuck?

You’ve billed for it, even been paid for it. But will you get to keep the money? And you can’t take the injection back…

This is like getting an injection with a barbed needle: feels ok going in, but coming back out it hurts like <insert your favorite expletive>.

For both providers and payers, there’s no confusion about one thing: injections and infusions can be tricky to properly bill.

Instruction Available

The eduTrax® site has two excellent courses available for their paid subscribers, and these can also be purchased as downloads or CDs. Short previews are available to give you an idea of their quality and content:

BLUE-PREVIEW-ON-Button Coding Injections and Infusions — reviews the recent changes to injections and infusions codes and offers guidance on correct capture of these services. (3 minute preview)

BLUE-PREVIEW-ON-Button RAC Focus: Injections & Infusions — discusses why, how & where physicians must be involved, and addresses code selection based upon time and service provided. (8 minute preview)

Click here to send us an Email for more information or to place an order.


Still No Medical Necessity Approvals

To date, there are still no issues posted & approved for review of Medical Necessity for any issue.

As usual, we wait…

Region B RAC Adds Review of Inpatient Admit Orders, 95 DRG Validations

RAC-LOGO-CGIIn the continuing posting of issues, the RAC contracted for the upper midwestern states, CGI Federal, has now joined Connolly Healthcare in its posting of an issue that can possibly recoup all Medicare Part A charges for an inpatient claim, and still not even touch the dreaded issue of Medical Necessity.

The List

Below are the 15 new issues, posted last week. Follow the links to each one, in the eduTrax RAC New Issue Database®, which can be seen with simple free registration at myedutrax.com.

1 Date of Death-DME
2 Inpatient Admissions without a Physician’s Inpatient Admit Order
3 MSDRG 052, 053, 054, 055, 056, 057, 058, 059, 060, 061, 062, 063, 067, 068, 069, 070, 071, 072, 073, 074, 077, 078, 079, 080, 081, 082, 083, 084, 085, 086, 088, 089, 090, 091, 092, 093, 097, 098, 099, 101, 102: DRG Validation for Nervous System Disorders
4 MSDRG 165: DRG Validation for Major Chest Procedures
5 MSDRG 168: DRG Validation for Other Respiratory System O.R. Procedures
6 MSDRG 175, 176, 180, 181, 182, 183, 184, 185, 186, 187, 188, 192, 196, 197, 198, 199, 200, 201, 202, 203, 204, 205, 206: DRG Validation for Respiratory
7 MSDRG 242, 243, 244: DRG Validation for Permanent Cardiac Pacemaker Implant
8 MSDRG 247, 249, 251: DRG Validation for Percutaneous Cardiovascular Procedures
9 MSDRG 326, 327, 328: DRG Validation for Stomach, Esophageal and Duodenal Procedures
10 MSDRG 371, 372, 373: DRG Validation for Major Gastrointestinal Disorders and Peritoneal Infections
11 MSDRG 405, 406, 407: DRG Validation for Pancreas, Liver and Shunt Procedures
12 MSDRG 474, 475, 476: DRG Validation for Amputation for Musculoskeletal System and Connective Tissue Disorders
13 MSDRG 490, 491: DRG Validation for Spinal Fusion
14 MSDRG 533, 534, 537, 538, 562, 563: DRG Validation for Musculoskeletal Fractures
15 Prosthetic Additions When Billed With Initial Or Preparatory Knee Prosthesis

More to Come

We’ll have more to say about the review of Physician orders, soon…

RACs Post New Issues in June

Three of the four RACs posted new issues recently. The Region A RAC, DCS, posted 39 new DRG Validations issues, plus an approved issue to review Evaluation & Management (E&M) codes for New Patient visits, mirroring the same issues already approved for other RACs.
Despite recent reports that issues including review of Medical Necessity have already been approved by CMS in at least one region, none of the RACs have yet to post any such approved issues.
The new issues are listed below, including links to their descriptions on eduTrax®. To see those pages, you will need to login to the eduTrax main site. Registration on the site is still free.

Region A

The RAC for Region A (DCS) posted several new issues, mostly for Automated Review:

1 Blood Transfusions
2 Bronchoscopy Services
3 Duplicate Claims – Part B
4 Global Billing of Radiology or Diagnostic Tests in the Facility Setting
5 Global Surgery – Pre and Post-Operative Visits
6 Global vs. TC/PC Split Reimbursements
7 IV Hydration
8 MSDRGs 177, 189, 193, 291, 438, 441, 444, 592, 602, 682, 689, 691, 693: MS-DRG Validation for Severe Sepsis
9 MSDRGs 216, 217, 218, 219, 220, 221: MS-DRG Validation for Cardiac Valve Procedures
10 MSDRGs 234, 236: MS-DRG Validation for Coronary Bypass
11 MSDRGs 335, 336, 337, 350, 351, 352, 353, 354, 355: MS-DRG Validation for Lysis of Adhesions
12 MSDRGs 463, 464, 465, 573, 574, 575, 901, 902, 903: MS-DRG Validation for Excisional Debridement
13 National Correct Coding Initiative – Part B
14 Neulasta
15 New Patient Visits
16 Newborn/Pediatric Codes
17 Once In A Lifetime
18 Parenteral Nutrition Additives with Premix Solutions
19 Technical Component of Radiology
20 Untimed Codes
21 Initial/Preparatory Knee Disarticulation Prosthesis
22 Manual Wheelchair Accessories Billed With Power Wheelchair Bases

Region C

Connolly added two DRG Validations and one issue for Automated review:

1 Lymphoma and Nonacute Leukemia with MCC: MS-DRG 840
2 Percutaneous Cardiovascular Procedure with Drug-Eluting Stent without MCC: MS-DRG 247
3 Zoledronic acid, (Zometa) – Dose vs. Units Billed

Region D

HDI added a single issue for Automated review, concerning Discharge Status:

1 Incorrect Patient Status – Acute

Every wonder about what difference a Discharge Status code makes for your reimbursement? Take a look at the Transfer DRG Assistant® at the eduTrax site. The complete tool includes all DRGs, all the Discharge Codes with explanations, and can show you an estimated difference in reimbursement based upon length of stay, the DRG assigned, and the appropriate status code, which is determined by where a patient may (or may not) wind up going after discharge from your facility.

Making Your Own RAC Issues Lists?

Good luck, we know how hard it is to do. To find a complete, sortable listing of all the RACs’ posted issues, visit this page on eduTrax. (Registration required.)

We recommend viewing the list, sorted by Approved Date.

To see the complete original listings (on the RAC websites), visit this page.

When Will Medical Necessity Reviews Begin?

No one knows but the RACs, and so far, they ain’t sayin’.

BUT — If you would like to be notified immediately whenever they do get posted, simply to the click here to subscribe for free to the eduTrax RAC New Issues Alert Service®.

We post new issues, as in this article, and will send out an email notice immediately when medical necessity issues begin posting on the RAC websites.

More Issues and Medical Necessity Expected Any Day

CMS May Have Already Approved Medical Necessity Reviews

During the May 5, 2010 RAC 101 Conference Call, Scott Wakefield, a CMS RAC Project Manager for Region B stated that providers may begin to receive RAC medical necessity reviews “within the next month or so.” According to one observer, he seemed somewhat surprised that no such reviews have been posted by the RACs, as yet, and intimated that such issues had already been approved.

Meanwhile, in the past two weeks, the RAC have all posted new issues, but none with medical necessity reviews approved.

The new issues are listed below, including links to their descriptions in the eduTrax® RAC New Issues pages. To see those pages, you will need to login to the eduTrax main site. Registration on the site is still free.

Region A

While the RAC for Region A (DCS) only posted one new issue, it is not exactly inconsequential:

MS-DRG Validation for HIV — Reviewers will validate claims where diagnosis code 042 Human Immunodeficiency Virus (HIV) Disease was billed as secondary.

This is currently the only DRG Validation issue that cannot be specifically tied to a single MSDRG. This issue involves any DRG where HIV appears as a secondary diagnosis.

Region B

CGI Federal added two new issues: one Automated Review and one that includes 3 DRG Validations:

Knee Orthoses — concerns certain additions not being separately payable.

MSDRG 239, 240, 241: DRG Validation for Amputation for Circulatory System Disorders Except Upper Limb and Toe.

This site remains the most difficult to track – it is designed to require human interaction across eight pages of issues.

Region C

Connolly Healthcare posted 19 new issues, including 21 new DRG Validations:

Darbepoetin alfa (non-ESRD) – Dose vs. Units Billed
Bevacizumab – Dose vs. Units Billed
Carboplatin – Dose vs. Units Billed
Docetaxel – Dose vs. Units
Irinotecan – Dose vs. Units Billed
Darbepoetin alfa (ESRD) – Dose vs. Units Billed
MS-DRG 040: Peripheral/Cranial Nerve and Other Nervous System Procedures with MCC
MS-DRG 841: Lymphoma and Nonacute Leukemia with CC
MS-DRG 258: Cardiac Pacemaker Device Replacement with MCC
MS-DRG 653: Major Bladder Procedure with MCC
MS-DRG 659: Kidney and Ureter Procedures for Non-Neoplasm with MCC
MS-DRG 326: Stomach, Esophageal and Duodenal Procedures with MCC
MS-DRG 009: Bone Marrow Transplant: MS-DRG 009
MS-DRG 328: Stomach, Esophageal and Duodenal Procedures without CC/MCC
MS-DRG 623: Skin Grafts and Wound Debridement for Endocrine, Nutritional & Metabolic Disorders w/CC
MS-DRG 802: Other O.R. Procedures of the Blood and Blood-Forming Organs with MCC
MS-DRGs 034, 035, 036, 215, 223, 224, 225, 231, 232, 286: Cardiac Procedures
MS-DRG 541: Osteomyelitis without CC/MCC
DME vs. Inpatient

Region D

Even HDI added a new issue for Automated Review:

Part B Duplicates – Automated Review

Making Your Own Lists?

Good luck, we know how hard it is to do.  To find a complete, sortable listing of all their posted issues, visit this page on eduTrax. (Registration required.) We recommend viewing the list, sorted by Approved Date.

To see the complete original listings (on the RAC websites), visit this page.

When Will Medical Necessity Reviews Begin?

No one knows but the RACs, and so far, they ain’t sayin’.

BUT — If you would like to be notified immediately whenever they do get posted, simply to the click here to subscribe for free to the eduTrax RAC New Issues Alert Service®.

We post new issues, as in this article, and will send out an email notice immediately when medical necessity issues begin posting on the RAC websites.

Connolly Adds 20 More in April

More High Dollar, High Volume DRGs

Connolly Healthcare, the RAC for Region C, posted 20 new DRG Validation Issues to their list of CMS-Approved audit issues, on Friday, April16. The list includes eight (8) MS-DRGs with very high Relative Weights (which equates to high dollar reimbursements and thereby potentially high RAC fees) and six (6) with claim volumes in the top 25% of all DRGs (providing a rather large number of claims to potentially audit).

Four (4) of the newly approved issues are for MSDRGs with Relative Weights of better than 10.0.  Such claims have high dollar reimbursements, averaging over $45,000 per claim, nationwide.

Once again, these approval/postings seems to continue a pattern previously noted. (See our posts from February 9 and March 17.)

Virgina and West Virginia Now Included

The states of Virginia and West Virginia have been absent from the list of states affected or approved for any issues, until some recent changes to the lists, earlier in April. Still, not all the issues have been approved for these two states.

The New Issues

Below are the new posted and approved audit issues for RAC Region C, including Relative Weights and FY09 Discharge Ranks:  (a low rank number relates to a large number of discharges for that DRG, nationwide)

  • MS-DRG 003: ECMO or Tracheotomy with Mechanical Ventilation 96+ Hours or Principal Diagnosis Except Face, Mouth and Neck with Major O.R. (RW 18.27; Rank 122)
  • MS-DRG 001: Heart Transplant or Implant of Heart Assist System with MCC (RW 24.85; Rank 720)
  • MS-DRG 005: Liver Transplant with MCC or Intestinal Transplant (RW 10.14; Rank 713)
  • MS-DRG 332: Rectal Resection with MCC (RW 4.78; Rank 297)
  • MS-DRG 562: Kidney Transplant (RW 1.38; Rank 79)
  • MS-DRG 011: Tracheotomy for Face, Mouth, and Neck Diagnoses with MCC (RW 4.73; Rank 476)
  • MS-DRG 012: Tracheotomy for Face, Mouth, and Neck Diagnoses with CC (RW 3.03; Rank 584)
  • MS-DRG 020: Intracranial Vascular Procedures with Principal Diagnosis of Hemorrhage with MCC (RW 8.44; Rank 696)
  • MS-DRG 021: Intracranial Vascular Procedures with Principal Diagnosis of Hemorrhage with CC (RW 6.21; Rank 696)
  • MS-DRG 927: Extensive Burns or Full Thickness Burns with Mechanical Ventilation 96+ Hours with Skin Graft (RW 13.74; Rank 629)
  • MS-DRG 929: Full Thickness Burn with Skin Graft or Inhalation Injury without CC/MCC (RW 2.01; Rank 728)
  • MS-DRG 023: Craniotomy with Major Device Implant/Acute Complex Central Nervous System Principal Diagnosis with MCC or Chemo Implant (RW 4.94; Rank 469)
  • MS-DRG 024: Craniotomy with Major Device Implant/Acute Complex Central Nervous System Principal Diagnosis without MCC (RW 3.26; Rank 212)
  • MS-DRG 007: Lung Transplant (RW 9.45; Rank 689)
  • MS-DRG 076: Viral Meningitis without CC/MCC (RW 0.83; Rank 510)
  • MS-DRG 461: Bilateral or Multiple Major Joint Procedures of Lower Extremity with MCC (RW 4.56; Rank 187)
  • MS-DRGs 799, 800, 801: Splenectomy w MCC, w CC, w/o CC/MCC (RW 5.11, 2.53, 1.59; Ranks 666, 709, 620)
  • MS-DRG 177: Respiratory Infections & Inflammations with MCC (RW 2.05; Rank 35)
  • MS-DRG 178: Respiratory Infections & Inflammations with CC (RW 1.49; Rank 132)
  • MS-DRG 179: Respiratory Infections & Inflammations without CC/MCC (RW 1.01; Rank 119)

To see the complete original listings (on the RAC websites), visit this page.

Or, to find a more useful listing of all their posted issues, visit  this page on eduTrax.  (Registration required.)

Still No Medical Necessity Reviews

All of the above approved issues still include this caveat:

(At this time, Medical Necessity excluded from review).

As faithful readers know, however, Medical Necessity Reviews could be approved by CMS at any time now, since the CMS RAC Review Phase-In Strategy allows for such audits in calendar 2010.

We will shortly post further analysis, in an overview of the DRG Validations posted to date by all four RACs.

Connolly Adds Yet Another 25 New Issues

Several with High Rankings, High Dollar Value

Connolly Healthcare, the RAC for Region C, posted 25 new DRG Validation Issues to their list of CMS-Approved audit issues, on Tuesday, March 16. Once again, Connolly has been approved for even more MS-DRGs with high Relative Weights (which equates to high dollar reimbursements) and high claim volumes (which equates to large number of claims to potentially audit).

Three (3) of the newly approved issues are for MSDRGs with Relative Weights of better than 5.0.  Also, six(6) of the 25 new issues are ranked (by number of discharges)  in the top 100 DRGs nationwide.

This latest round of approval/postings seems to continue a pattern we have previously noted here. (See our post from February 9.)

Noteably, the states of Virginia and West Virginia are still absent from the list of states affected or approved for any of these issues. The 13 states affected by these approved issues are: Alabama, Arkansas, Colorado, Florida, Georgia, Louisiana, Mississippi, New Mexico, North Carolina, Oklahoma, South Carolina, Tennessee, Texas.

The List

Below are the new posted and approved audit issues for RAC Region C:

  1. MS-DRG 226: Cardiac Defibrillator Implant without Cardiac Catheterization with MCC 
  2. MS-DRG 415: Cholecystectomy Except by Laparoscope without C.D.E. with CC 
  3. MS-DRG 237: Major Cardiovascular Procedures with MCC or Thoracic Aortic Aneurysm Repair 
  4. MS-DRG 969: HIV with Extensive O.R. Procedure with MCC 
  5. MS-DRG 933: Extensive Burns or Full Thickness Burns with Mechanical Ventilation 96+ Hours without Skin Graft 
  6. MS-DRG 239: Amputation for Circulatory System Disorders Except Upper Limb and Toe with MCC 
  7. MS-DRG 934: Full Thickness Burn without Skin Graft or Inhalation Injury 
  8. MS-DRG 243: Permanent Cardiac Pacemaker Implant with CC 
  9. MS-DRG 246: Percutaneous Cardiovascular Procedure with Drug-Eluting Stent with MCC or 4+ Vessels/Stents 
  10. MS-DRG 253: Other Vascular Procedures with CC 
  11. MS-DRG 749: Other Female Reproductive System O.R. Procedures with CC/MCC 
  12. MS-DRG 803: Other O.R. Procedures of the Blood and Blood-Forming Organs with CC 
  13. MS-DRG 823: Lymphoma and Nonacute Leukemia with Other O.R. Procedure with MCC 
  14. MS-DRG 315: Other Circulatory System Diagnoses with CC 
  15. MS-DRG 617: Amputation of Lower Limb for Endocrine, Nutritional, and Metabolic Disorders with CC 
  16. MS-DRG 829: Myeloproliferative Disorders or Poorly Differentiated Neoplasms with Other O.R. Procedure with CC/MCC 
  17. MS-DRG 486: Knee Procedures with Principal Diagnosis of Infection with CC 
  18. MS-DRG 941: O.R. Procedure with Diagnoses of Other Contact with Health Services without CC/MCC 
  19. MS-DRG 577: Skin Graft and/or Debridement Except for Skin Ulcer or Cellulitis with CC 
  20. MS-DRG 358: Other Digestive System O.R. Procedures without CC/MCC 
  21. MS-DRG 133: Other Ear, Nose, Mouth and Throat O.R. Procedures with CC/MCC 
  22. MS-DRG 424: Other Hepatobiliary or Pancreas O.R. Procedures with CC 
  23. MS-DRG 616: Amputation of Lower Limb for Endocrine, Nutritional, and Metabolic Disorders with MCC 
  24. MS-DRG 675: Other Kidney and Urinary Tract Procedures without CC/MCC 
  25. MS-DRG 717: Other Male Reproductive System O.R. Procedures except Malignancy with CC/MCC 

To see the complete original listings (on the RAC websites), visit this page.

Or, to find a more useful listing of all their posted issues, visit  this page on eduTrax.  (Registration required.)

Still No Medical Necessity Reviews

All of the above approved issues still include this caveat:

(At this time, Medical Necessity excluded from review).

We again remind everyone that Medical Necessity Reviews could be approved by CMS at any time now, since the CMS RAC Review Phase-In Strategy allows for such audits in calendar 2010.

Stay tuned, as the situation unfolds.

RAC Record Request Letter from Connolly (Region C)

Below is a link to an Additional Documentation Request Letter (ADR) letter from Connolly to a hospital in Georgia. It only requests 5 records, but is only the first they’ve received, and is dated Feb 25, 2010.

Download this letter, HERE.

Here are a few things we’ve noted about the letter:

DRG Validations for the following MSDRGs –

  • MSDRG 981 – OR Procedure unrelated – RW 5.04, Rank 134, ALOS 14.6 – claim shows 7 day stay.
  • MSDRG 386 – Inflammatory Bowel Disease – RW 1.04, Rank 343, ALOS 5.4 – shows 6 day stay.
  • MSDRG 574 – Skin Graft &/or Debridement – RW 1.91, Rank 352, ALOS 8.9 – shows 5 day stay.
  • MSDRG 574 – Skin Graft &/or Debridement – RW 1.91, Rank 352, ALOS 8.9 – shows 4 day stay.
  • MSDRG 357 – Other Digestion System OR Procedure – RW 2.12, Rank 468, ALOS 7.7 – shows 3 day stay.

Abbreviations used, above:

  • OR = Operating Room
  • RW = Relative Weight for reiumbursement
  • Rank = nationwide rank, reported by CMS, by number of discharges in FY09 (#1 = highest)
  • ALOS = Average Length of Stay in days

In the letter, note that the Rationale for each DRG Validation mentions that “the RAC Demonstration … found an overwhelming majority of errors in assignment… resulting in overpayments to hospitals.

The letter then goes on to state: “The RAC identified errors in the data that could be traced to the hospitals’ medical record practice. An analysis of your billing data indicates that a potential aberrant billing practice may exist for this DRG.

Interesting wording… note the use of “hospitals‘” (plural); and “your billing data” — the letter does not make clear what analysis the RAC really did.

Region C RAC Adds 19 New Issues

Connolly Posts 19 New DRG Validation Issues

February 9, 2010 — Connolly Healthcare, the RAC for Region C (south & southeastern states), posted 19 new approved issues for review on their RAC Issues page, on Monday, February 8, 2010. Following the format they have been using to date, the listed issues include only single MS-DRGs, but are still not listed in any particular order.

All of the new issues are approved for DRG Validation, affecting all thirteen of the Region C states (AL, AR, CO, FL, GA, LA, MS, NM, NC, OK, SC, TN, TX).

Top Ranked, High Dollar DRGs Added

Give their demonstrated proclivity to review high-dollar DRGs, these additions are not surprising, coming from Connolly.

See our recent analysis done for RAC Monitor, HERE.

We will shortly post another analysis of their approved issues list, analyzing the posted issues by DRG Relative Weights and by DRG Rank (in terms of the number of discharges, nationwide). Of the 52 DRGs with Relative Weights of better than 5.0, Connolly just added four (4) more to their list. Six(6) of the 19 new issues are ranked (by number of discharges)  in the top 100 DRGs nationwide.

Three States Added to Previously Posted Issues

Notably, Arkansas, Lousiana and Mississippi were added to the states affected lists for all previously approved DRG Validation issues, now bringing them fully under the magnifying glass of the RAC. These three states were added to the posted DRG Validation issues on February 2.

Still No Medical Necessity Reviews

None of the posted issues are approved for review of Medical Necessity, and such reviews do not appear to have been approved for any of the RACs, to date. However, it is likely that the existing DRG Validation issues will all be approved for medical necessity review in short order, since the CMS RAC Review Phase-In Strategy allows for such approvals in calendar 2010.

More Useful Lists Available

Find links to all the RAC New Issues Pages here. For more useful lists, see below.

Use the links below to see details of the newly posted issues, in our database (Editor’s Note: this list appears here in the reverse order as posted by Connolly):

1 MS-DRG 208: Respiratory System Diagnosis with Ventilator Support
2 MS-DRG 038: Extracranial Procedures with CC
3 MS-DRG 227: Cardiac Defibrillator Implant without Cardiac Catheterization without MCC
4 MS-DRG 240: Amputation for Circulatory System Disorders Except Upper Limb and Toe with CC
5 MS-DRG 242: Permanent Cardiac Pacemaker Implant with MCC
6 MS-DRG 957: Other O.R. Procedures for Multiple Significant Trauma with MCC
7 MS-DRG 344: Minor Small and Large Bowel Procedures with MCC
8 MS-DRG 488: Knee Procedures without Principal Diagnosis of Infection with CC/MCC
9 MS-DRG 533: Fractures of Femur with MCC
10 MS-DRG 216: Cardiac Valve and Other Major Cardiothoracic Procedures with Cardiac Catheterization with MCC
11 MS-DRG 460: Spinal Fusion Except Cervical with MCC
12 MS-DRG 248: Percutaneous Cardiovascular Procedure with Non Drug-Eluting Stent with MCC or 4+ Vessels/Stents
13 MS-DRG 222: Cardiac Defibrillator Implant with Cardiac Catheterization with Acute Myocardial Infarction/Heart Failure/Shock with MCC
14 MS-DRG 201: Pneumothorax without CC/MCC
15 MS-DRG 945: Rehabilitation with CC/MCC
16 MS-DRG 470: Major Joint Replacement or Reattachment of Lower Extremity without MCC
17 MS-DRG 885: Psychoses
18 MS-DRG 291: Heart Failure and Shock with MCC
19 MS-DRG 189: Pulmonary Edema and Respiratory Failure

Find a list of all their posted issues HERE.  (Registration required.)

Connolly Posts Over 40 New Issues

Connolly Healthcare, Region C RAC, posted over 40 new issues, all for Complex Reviews, most for Inpatient Hospitals, during the final week of December, 2009. Happy New Year! The total number of issues now approved for Connolly’s review is over 75. Most of those issues will review MS-DRG coding and DRG Validation, but those all include the following phrase in their title:

At this time, Medical Necessity excluded from review.

Of course, this could change at any time now, since CMS plans to allow Medical Necessity to be reviewed, beginning in calendar 2010. (See CMS RAC Review Phase-in Strategy)

Non-User Friendly Lists

However, as we discovered in this past quarter, since the RACs began posting new issues, as they are required to do by CMS, we noticed that the WAY in which they post the new issues is not consistent, from RAC to RAC. What’s worse, there seems to be no effort on the part of the RAC to make that information easy to sort, copy, or deal with in any useful form. That is, you can’t sort the list, you can’t make a decent copy of it, you can’t even see all the data you might like to know on each issue.

Changes Made Without Notice

The worst part, however, is the way that the RACs do their postings: willy-nilly. In other words, they just throw the posts up there. There is no notice sent or made about a new post being added and/or changed. When new issues are added, there is also no effort made to group similar issues together. For example, on the Connolly list, some of the DRG Validation issues involve all three of an MS-DRG triplet (a triplet is an MS-DRG “group,” if you will, a set of three MS-DRGs that represent all three severity levels assigned by CMS to that diagnosis — e.g., Pneumonia is assigned a triplet, 193/194/195, representing Pnuemonia with an MCC, with just a CC, or without MCC or CC). This is not huge, but it certainly makes it difficult to work with the list.

Needless Complexity

For example, we know of one hospital in Region C that received a single letter requesting 24 medical records, one for each of 24 different MS-DRGs. The MS-DRGs were simply listed by number, with no descriptions. For a coding department, this is not a huge problem. However, for a RAC Team, it is an issue. Why? Because the letter probably has to travel thru several hands to get to the Coding department, who then have to look up the codes, add the descriptions, and then send the letter back up the path to all concerned parties, so that they know what they’re doing.

How much time did that just add to the time it takes to identify, find, copy and send off those records to the RAC? Providers are already under the gun to get the records back to the RAC, and this makes the process all that much more difficult. And needlessly!

A New Way to See the New Issues

For our own internal use, eduTrax developed it’s own database of the new issues, and we are pleased to now make that database available to providers, for their use.

The RAC News Issues Page provides direct links to the four RAC websites. You need not register or login to see these links. Simply go HERE, and choose one of the RAC links.

The RAC New Issues Menu requires you to register, which is free and takes only a minute to do. (You will have to confirm your email address, as a security measure.) Once you login to the site, select the RAC New Issues Page, and a new menu will appear on your left. (preview here)

eduTrax® RAC New Issues Alert Services

This new service now gives you the following choices:

  • See New Issues by each RAC — but in a list that is sortable and searchable,
  • See New Issues by State — click your state, get a list of the issues approved for that state.

We keep the database updated daily. Currently, we are changing the Issue Title, in our database, so that it is more friendly. For example, we put the MS-DRG number at the front of the title. This makes it easier to search and sort.

To search for an MS-DRG, simply enter the number alone in the Title Search field, then hit Go.

To sort any list by title, simply click on “Issue Title” at the top of the list.

Go HERE to see some instructions on using the sort and search filters.

Soon, we will announce an eMail Alert Service — you get an email from us whenever a RAC posts or changes an issue, and the email will include what got added and/or changed. That way, you stay alerted, and you don’t have to figure out what changed — we do it for you!

More Coming Soon…

So, we recommend you go look at the lists yourself. And watch for the announcement about our new Alerts services.

Also, our next post will include some analysis of the new issues, and what you need to be looking for.

Connolly Posts 25 New Issues

Complex RAC Reviews Have Begun

The first Coding & DRG Validation issues approved for RAC audits have been posted on the Connolly website. The MS-DRGs selected are not surprising, given the history of the RAC Demonstration findings, and the dollar potential for take-backs.

To see the complete original listings, visit this page on eduTrax.

Are you ready? Really? Note the emphasis on “attending physician description (documentation)” in the posts by Connolly.

In the next few days, we will post some commentary on what we would advise providers to be looking into, in preparation for the doubtless onslaught of record requests and subsequent denials that this event precedes.

The following 25 items were ADDED, for all States in Region C:

  1. Upper Limb and Toe Amputation for Circulatory System Disorders with MCC: MS-DRG 255
  2. Cirrhosis and Alcoholic Hepatitis with MCC: MS- DRG 432
  3. Septicemia without Mechanical Ventilation 96+ Hours without MCC: MS-DRG 872
  4. Nonextensive O.R. Procedure Unrelated to Principal Diagnosis without CC/MCC – MS-DRG 989
  5. Nonextensive O.R. Procedure Unrelated to Principal Diagnosis with MCC: MS-DRG 987
  6. Other Respiratory System O.R. Procedures without CC/MCC: MS-DRG 168
  7. Extensive O.R. Procedure Unrelated to Principal Diagnosis without CC/MCC: MS-DRG 983
  8. Extensive O.R. Procedure Unrelated to Principal Diagnosis without CC/MCC: MS-DRG 983
  9. Other Respiratory System O.R. Procedures with CC: MS-DRG 167
  10. Other Digestive System Diagnoses with CC: MS-DRG 394
  11. Inflammatory Bowel Disease with CC: MS-DRG 386
  12. Major Gastrointestinal Disorders and Peritoneal Infections without CC/MCC: MS-DRG 372
  13. Other Respiratory System O.R. Procedures with MCC: MS-DRG 166
  14. Major Small and Large Bowel Procedures without CC/MCC: MS-DRG 331
  15. Major Small and Large Bowel Procedures with CC: MS-DRG 330
  16. Major Small and Large Bowel Procedures with MCC: MS- DRG 329
  17. Major Chest Procedures without CC/MCC: MS-DRG 165
  18. Major Chest Procedures with MCC: MS-DRG 163
  19. Major Chest Procedures with CC: MS-DRG 164
  20. Respiratory System Diagnosis with Ventilator Support 96+ Hours: MS-DRG 207
  21. Septicemia without Mechanical Ventilation 96+ Hours with MCC: MS-DRG 871
  22. Extensive O.R. Procedure Unrelated to Principal Diagnosis with MCC: MS-DRG 981
  23. Extensive O.R. Procedure Unrelated to Principal Diagnosis with CC: MS-DRG 982
  24. Nonextensive O.R. Procedure Unrelated to Principal Diagnosis with CC – MS-DRG 988
  25. Coagulation Disorders: MS-DRG 813

We note that Septicemia, while only listed once above, is bound to be a major target area, due to its very nature.

No Medical Necessity Reviews, As Yet

All of the above include this caveat:

(At this time, Medical Necessity excluded from review).

Of course, all this means is that such review is postponed until Jan 1, 2010, when such reviews can be conducted. Anything a provider must submit before then has direct potential to be audited for exactly that — Medical necessity — after January 1.

Sparse Descriptions, As Yet

All the above are described and listed with similar notes, as follows:

Description:

DRG Validation requires that diagnostic and procedural information and the discharge status of the beneficiary, as coded and reported by the hospital on its claim, matches both the attending physician description and the information contained in the beneficiary’s medical record.  Reviewers will validate for MS DRG {XXX}, principal diagnosis, secondary diagnosis, and procedures affecting or potentially affecting the DRG.

Provider Type Affected:   Inpatient Hospital

Date of Service: 10/01/2007 – Open

States Affected: Alabama, Colorado, Florida, Georgia, New Mexico, North Carolina, Oklahoma, South Carolina, Tennessee, Texas

Additional Information:

Additional information can be found on the following manuals/publications:

ICD-9-CM for Hospitals Vol. 1, 2 & 3, Coding Guidelines, Section II, A, B, C, D, E, F, G, H (2007 – 2009)

ICD-9-CM Addendums and Coding Clinics (2007 – 2009)

PIM Ch. 6.5.3, Section A-C  DRG Validation Review

Other Changes on the Connolly List

The following item CHANGED:

Once in a lifetime procedures

The following lines were ADDED to the Description:

Claims with modifier-58 will be excluded from your audit with dates of service starting 1/1/09.  Starting 1/1/09 this code was allowed to be billed more than once if the provider used the modifier.

Also, states were ADDED to the list of States Affected. The list now includes:

Alabama, Colorado, Florida, Georgia, North Carolina, New Mexico, Oklahoma, South Carolina, Texas

Stay tuned, as the situation unfolds.

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