CMS Releases Clarification on Reporting External Cause Codes and Unspecified Codes
By Betty Hovey, BA, CPC, CPC-I, CPC-H, CPCD, CCS-P, PCS, CCP, CIC, RMC
On May 17, 2013, the Centers for Medicare & Medicaid Services (CMS) released several important clarifications in their ICD-10 Industry Update email. There has been some confusion and frustration regarding the codes in Chapter 20, External Causes of Morbidity (V, W, X, and Y codes), which will replace the current ICD-9-CM E-Code section. The Official ICD-10-CM Guidelines (I.C.20) state that for any initial encounter from an illness or adverse effect, the codes found in this chapter should also be reported, along with the injury(ies) sustained. Many wondered if these codes in ICD-10-CM would be required by all payers, as not all payers currently require the E-codes to be assigned in ICD-9-CM. According to CMS, there will be no national stipulation for mandatory ICD-10-CM external cause code reporting. Unless a payer or state changes its current requirements, if you do not report external cause codes for ICD-9-CM, you will not report external cause codes in ICD-10-CM.
CMS also addressed usage of unspecified codes in ICD-10-CM. There are many more specific codes in ICD-10-CM when compared to ICD-9-CM (about 5 times as many), but unspecified codes are still part of the code set. CMS states that unspecified codes have acceptable, even necessary uses in ICD-10-CM. The coding guidelines state that each encounter should be coded to the highest level of specificity known. CMS further comments that it is inappropriate to either select a specific code that is not supported by the medical record documentation or conduct medically unnecessary diagnostic testing in order to determine a more specific code. When sufficient clinical information is not known or available to assign a more specific code, an unspecified code may be the most appropriate code to report.
These concepts had already been incorporated into AAPC’s industry-wide ICD-10 training; the clarifications are welcome.