Code surgically treated pressure ulcers that fail as complications of either a skin or tissue transplant, from the T86.8- subcategory (Complications of other transplanted organs and tissues).
Home health agencies deal with these types of pressure ulcer treatment complications frequently so knowing how to code them is important. Skin grafts and muscle flap procedures “fail all the time,” says Ann Rambusch, HCS-D, president of Rambusch3 Consulting in Georgetown, Texas.
Select the specific code based on whether the treatment involved a skin graft or a muscle flap. For example, an alphabetic index query for “complication, transplant, skin, failure” on the Home Health Coding Center leads directly to T86.821 (Skin graft (allograft) (autograft) failure).
The path to the code for a failed muscle flap is less clear given that there isn’t a specific listing for this type of complication in the index. Thus, the appropriate code choice is found in the “specified tissue NEC” option, which is T86.891 (Other transplanted tissue failure). A query on the Coding Center for “complication tissue transplant failure” will lead you directly to that code.
Be sure to also assign the code for the unstageable pressure ulcer that the skin graft or muscle flap was performed to treat as long as the graft or flap is still obscuring the wound bed, according to coding guidelines. And, note the guideline that instructs you to assign an additional code for the specific complication in addition to the T86.- code. [I.C.19.g.3.a]
If all you know is that the skin graft failed but not specifically why, T86.821 along with the code for the unstageable pressure ulcer is sufficient, says Brandi Whitemyer, HCS-D, an independent home health and hospice consultant in Canton, Ohio.
But if documentation states that the skin graft failed due to infection, for example, assign an additional code for the infection, Whitemyer says.
Tip: Code the pressure ulcer at its worst stage when a failed skin graft or muscle flap exposes the wound thus making it stageable again, Whitemyer says.
CMS’ long-awaited draft version of the interpretive guidelines for the revised Home Health Conditions of Participation (CoPs) provides agencies some clarity about what surveyors might focus on and how to avoid citations beginning Jan. 13, 2018.
Agencies should study this guidance immediately and use it to prepare for the CoPs.
Understand as well that the 85-page draft released Oct. 27 shows CMS is marching forward with plans to enforce the revised CoPs, contends Arlene Maxim, vice president of program development with Quality in Real Time (QIRT) in Floral Park, N.Y. For agencies waiting until the last minute to prepare, they better get to work.
CMS is collecting comments on the draft guidelines, and a final version is expected to be released in December.
Unfortunately, agencies will have to wait until that release to see how CMS will change the state operations manual as a result of the revised CoPs, says attorney Robert Markette of Indianapolis-based Hall, Render, Killian, Heath & Lyman. That means broader survey guidance on the revised CoPs, which would detail how survey guidelines will break down into level 1 and level 2 standards, isn’t currently available to view.
Agencies in the Pacific region will see a payment increase of 0.6% in 2018, the best deal under CMS’ policies. Meanwhile, agencies in the East South Central region will see the biggest reduction, -1.6%.
Note: CMS will decrease payments for rural providers by 2.5% and decrease payments for urban providers by 0.1%.
|Area of the country||Effect of 2018 policies|
|New England (Conn., Maine, Mass., N.H., R.I. Vt.)||0.0%|
|Middle Atlantic (Pa., N.J., N.Y.)||-0.1%|
|South Atlantic (Del., D.C., Fla., Ga., Md., N.C., S.C., Va., W.Va.)||-0.5%|
|East South Central (Ala., Ky., Miss., Tenn.)||-1.6%|
|West South Central (Ark., La., Okla., Texas)||-0.7%|
|East North Central (Ill., Ind., Mich., Ohio, Wis.)||-0.1%|
|West North Central (Iowa, Kan., Minn., Mo., Neb., N.D., S.D.)||-0.4%|
|Mountain (Ariz., Colo., Idaho, Mont., Nev., N.M., Utah, Wyo.)||-0.4%|
|Pacific (Alaska, Calif., Hawaii, Ore., Wash.)||0.6%|
|Other (Guam, Puerto Rico, Virgin Islands)||-1.3%|
|Source: 2018 final PPS rule|