From 3M Health Information Systems
ICD-10 updates twice a year? More COVID-19 code proposals? Highlights from the March C&M meeting
The latest ICD-10 Coordination and Maintenance Committee (C&M) meeting gave us one more unprecedented thing in this time of unprecedented things—the combined agenda was the largest ever. The two-day virtual meeting, held March 9 and 10 and sponsored jointly by CMS and the CDC, was stuffed with proposals. Maybe the correlation between working from home and increased productivity applies here too? At any rate, there were so many procedure proposals that for the first time CMS wrote the exact 15-minute slot next to each topic on the agenda—and stuck to it. Also, for the first time, a month before the meeting CMS posted code proposals online for public review and comment and announced that these proposals would not be presented or discussed at the meeting—there were not enough 15-minute slots to go around, and this is a 9-to-5 deal!
Speaking of time, that slippery eel… below are a few highlights from diagnosis and procedure code proposals for those who don’t have it in them to troll through day-long Zoom recordings. For more detail on the proposals, there is a PDF with all diagnosis code proposals on the CDC website, and ditto for the procedure code proposals, available on the CMS website.
More COVID-19 ICD-10-CM/PCS Codes Proposed
Both diagnosis and procedure codes for COVID-related conditions and treatment were proposed. Instead of the previous emergency updates, this time they are proposed for October 1, 2021 implementation.
A new diagnosis code (page 96 of the CDC agenda), U09.9 Post COVID-19 condition, unspecified, is proposed to establish a link in the medical record between COVID-19 and conditions that persist after the person no longer has COVID-19. Examples given are chronic respiratory failure, loss of taste or loss of smell. The persistent condition is coded first, followed by the proposed new code.
Four new procedure codes (page 108 of the CMS agenda) are proposed for the intravenous infusion of two additional substances that may be administered to patients hospitalized for treatment of COVID-19. The substances are Hyperimmune Globulin and High-Dose Intravenous Immune Globulin. Brand names such as Octagam 10%, GAMUNEX-C and common acronyms (HIG, hdIVIG), are proposed for the PCS Substance Key and Index, to help coders with code assignment.
Gauging Public Interest in Twice Annual Updates
ICD-10 may be moving to biannual updates —April 1, in addition to October 1—depending on public comment (page 50 in the CMS agenda). CMS and CDC jointly announced that the possibility of a regular April 1 update to ICD-10 is under consideration. CMS is taking the lead in the discussion and collection of public comment. You can send comments anytime until May 7, 2021 to CMS at ICDProcedureCodeRequest@cms.hhs.gov.
By law, the current use of April 1 for an interim implementation of new ICD-10 codes is highly constrained—emerging diseases and qualifying NTAP (New Technology Add-on Payment) proposals only. As far as I know we have never had an April 1 update for procedure codes, and in 2020 the “scheduled” April 1 update, one diagnosis code to capture the use of vaping, was all but forgotten in the “unscheduled” introduction of new COVID-19 codes and the ensuing year-long scramble to update, and update, and update. We have discovered that a pandemic does not wait for arbitrary dates like April 1 and October 1—emergency updates happen when they happen. So, the idea under discussion is to broaden the use of an April 1 update to include, for example, new codes discussed at the September C&M meeting.
Keep in mind, this is only an announcement to open the discussion and ask for feedback. In the writeup, CMS asks specifically for feedback on “how it may impact your current business processes” and “what factors the Committee should consider when determining which requests should be considered for either an April 1 or October 1 implementation date.”
Long-awaited SDOH Codes
The result of a national collaboration convened in 2019 and called the Gravity Project, this proposal (pages 122-128 of the CDC agenda) requests a number of new codes to capture specific data elements identified by the project in domains such as education, homelessness, housing instability, food and transportation insecurity, financial insecurity or hardship, inadequate drinking water and others.
For example, instead of the current single code for homelessness, proposed new codes distinguish between sheltered homelessness (includes motels or other temporary/transitional living situations) and unsheltered homelessness (includes cars, parks and abandoned buildings in addition to living “on the street”).
AI-assisted Procedures, Bioprosthetic Artificial Heart, Customized 3D-printed Spinal Fusion Components and Much, Much More!
Entrepreneurship was on display at the March 9 procedure code session, with plenty of proposals applying for NTAP consideration. Many of them feature the use of AI to do things better and faster than unassisted human eyes and brains.
Transthoracic Echocardiography with Computer-Aided Image Acquisition (page 54 of the CMS agenda) uses a deep learning algorithm called a convolutional neural network (CNN) to give sonographers real-time guidance in obtaining diagnostic quality echocardiographic images.
Computer-Aided Mechanical Aspiration Thrombectomy (page 60 of the CMS agenda) is a system for removing thrombus from a vessel. The smarts in the catheter tip detect when the tip is in thrombus (as opposed to regular blood) so the aspiration pump only turns on the suction for the thrombus.
Two different software products (pages 40 and 47) use machine learning to “read” a CT scan or CT angiography and alert radiologists to pull an image from the queue when the software suspects positive findings—for stroke in one product, and for pulmonary embolism in the other.
Innovations in bioengineering were also well represented by a couple of firsts: the first bioengineered skin graft for thermal burn patients (page 37 of the CMS agenda) that includes both an epidermal and dermal layer and therefore mimics the structure and function of normal human skin; the first fully implantable artificial heart (page 43 of the CMS agenda) contains bioprosthetic surfaces and four biologic heart valves, in addition to a pump that is internal, electrohydraulic and autoregulated—all differences between this system and previous artificial heart systems.
Regrettably, I gave the diagnosis proposals short shrift, and believe it or not there is more cool stuff on the procedure agenda. If you can find time to click through the bookmarked PDFs, there may be proposals I didn’t mention that might interest you.
If you would like to comment on any of the diagnosis or procedure code proposals, below are the email addresses and deadlines.
For procedure code proposals, you can send comments by April 9, 2021 to CMS at ICDProcedureCodeRequest@cms.hhs.gov.
For diagnosis code proposals, you can send comments by May 10, 2021 to NCHS/CDC at nchsicd10CM@cdc.gov.
Rhonda Butler is a clinical research manager with 3M Health Information Systems.