Know How to Avoid Compliance Pitfalls and Support Accurate Cancer Dx Coding, Part 2
Understand how to document and support active or history Dx coding. In part 1 of this series, we looked at problems with cancer reporting identified by Office of Inspector General (OIG) auditors. Specifically, OIG investigators “use the terms ‘supported’ or ‘not supported’” in their reports “to denote whether or not the diagnoses codes submitted to the Centers for Medicare & Medicaid Services [CMS] by health plans in risk adjustment coding were evidenced in the medical records.” In other words, in their audits, the OIG was looking for documentation in office and progress notes, the history of present illness (HPI), physical exam (PE), and assessment & plan (A&P) that supported the diagnosis and, in turn, determined medical necessity for a patient’s treatment plan. At the center of the OIG’s audits is one very simple coding error, however: the distinction between coding for an active cancer that is receiving ongoing treatment or management, and coding for a history of cancer. The OIG reported that the documentation for the active diagnosis codes submitted in the audits reflected historical conditions, as there was no evidence of treatment or ongoing management and therefore the diagnosis codes reported were not supported. Understand When Cancer Is Regarded as Active In general, most types of cancer are considered an acute condition, and best practice would be to document active cancer in the A&P with support. When active cancer is undergoing treatment or management, support statements such as any of the following should be acceptable: Note for breast or ovarian cancer: For breast cancer diagnoses when the cancer is active, documentation must also include hormone receptor (HR) status for estrogen and/or progesterone, and human epidermal growth factor receptor (HER) status. When all three receptors are positive, documentation should include notation of HR+ and HER2+. This is also known as triple positive. When all three receptors are negative, documentation should include notation of HR- and HER2-. This is also known as triple negative, which is important as hormone therapy would not be used as treatment for triple-negative receptors. You should then code estrogen and progesterone HR and HER status with the appropriate codes from Z17.- (Estrogen, and other hormones and factors receptor status). Know When to Use a History Code Oncology coders often struggle with knowing when to start coding a history of cancer rather than active cancer, especially when the patient is on adjuvant hormone therapy. In diagnosis coding, per Guideline I.C.2 of the ICD-10-CM Official Guidelines for Coding and Reporting, “history of” means the condition is historical and no longer exists as current. This occurs when: Avoid Confusion Over Adjuvant Therapy The term “adjuvant” means “in addition to” and refers to medicine administered during or after an active cancer diagnosis and can be chemotherapy, radiation, immunotherapy, targeted therapy, or hormonal therapy. The purpose of the adjuvant medicine should be documented precisely, using language from the following list, as that will affect coding for active or historic cancer: Note additional breast, ovarian, or prostate cancer coding: Usually, when the patient undergoes adjuvant hormonal therapy for breast or ovarian cancer, the patient will have positive hormone receptors, and this can span many years. In this case, the neoplasm is considered malignant and active throughout the entire duration of hormone therapy treatment. Consequently, the cancer should be coded as active, and you should also observe these guidelines: Remember: Refer to ICD-10-CM to add other Z codes affecting estrogen receptors under Z79.8 (Other specified postprocedural states), such as Z15.0 (Genetic susceptibility to malignant neoplasm) or Z78.0 (Asymptomatic menopausal state). Learn From These Examples to Document Cancer Status and Treatment Correctly As we have seen, providers need to carefully document the purpose of the treatment and/or medication and the status of the cancer. The following examples illustrate how this affects coding. Example 1: The record states, “The patient is on adjuvant therapy for breast cancer. The patient had surgery, chemotherapy, and radiation five years ago, and is currently on tamoxifen and has been for five years.” This example presents two problems. First, the note doesn’t state the purpose of the drug (whether it is curative, palliative, or preventive). It also doesn’t say “cancer free” or “no NED.” The note is further missing HR+ and HER+ status, which is an essential factor for active cancer with ongoing adjuvant hormone therapy. In this situation, you will need to query the provider to see if you should report an active cancer diagnosis, as all the elements of the record should indicate the cancer is ongoing. A better note would read something like, “The patient has positive hormone receptors, or HR+ or ER+PR+ and is on adjuvant therapy, Tamoxifen for ten years to stop cell growth or for curative purposes. The patient had surgery, chemotherapy, and radiation five years ago.” Example 2: The record states, “Patient has history of breast cancer, status post-surgery/chemo/radiation and is on prophylactic tamoxifen for five years. There is no current evidence of disease.” In this case, you would report a history code, because the documentation notes “history of,” there is “no current evidence” of active condition, and the drug tamoxifen is being administered for preventive purposes. The bottom line: Without clear and concise documentation, coders may incorrectly report diagnosis codes, which could cause overpayment that will have to be repaid, or underpayment that will result in financial loss and that will affect the treatment and proper care of the patient. Delly Parham, CRC, CPMA, CPC, Risk Adjustment Coder
