More from the IPPS Proposed Rule: Present on Admission, Part 2

In my previous post, I discussed the CMS proposal for determining if beneficiaries acquired a condition or complication during their hospital stay. I also discussed the section of the Deficit Reduction Act (DRA) that required the identification of hospital-acquired conditions and the fact that beginning October 1, 2008, codes representing some of these conditions would not be considered during DRG assignment unless they were present on admission. In this post, I’ll discuss the specific hospital-acquired conditions that CMS is proposing to meet the DRA requirement.

CMS has partnered with the Centers for Disease Control and Prevention (CDC) to identify potential high-volume, hospital-acquired conditions that hospitals could have reasonably prevented, and to propose financial penalties for when they occur. CMS has also solicited input from hospitals associations and other organizations. CMS applied the following criteria to select these conditions:

• High cost, high volume, or both
• Assignment of a case to a DRG that has a higher payment when the code is present as a secondary diagnosis
• Could reasonably be prevented through the application of evidence-based guidelines
• Easily identified by unique ICD-9-CM codes

The FY 2008 IPPS proposed rule lists 13 potential conditions. These conditions are listed below in rank order:

1. Catheter-associated urinary tract infection
2. Pressure ulcers
3. Object left in during surgery
4. Air embolism
5. Delivery of ABO-incompatible blood products
6. Staphylococcus aureus septicemia
7. Ventilator-associated pneumonia
8. Vascular catheter-associated infections
9. Clostridium difficile-associated disease
10. Methicillin-resistant staphylococcus aureus infection
11. Surgical site infections
12. Surgery on wrong body part, wrong patient, or wrong surgery
13. Patient falls

CMS is proposing the first six conditions best meet the above statutory selection criteria. The remaining conditions may meet the selection criteria but present some challenges which are outlined in detail in the proposed rule. CMS is seeking public comment on the first six conditions as well as the seven additional conditions to determine which to implement for FY 2009.

• The ranking of the conditions
• Clinical, coding and prevention issues that may affect the conditions selected
• Reasons for including conditions not on the top of the list
• How many and which conditions should be selected for implementation on October 1, 2008