Part 2: CMS announces new ICD-10-PCS codes to capture COVID-19 therapeutics

By now you are probably aware that the Centers for Medicare and Medicaid Services (CMS) issued 12 new ICD-10-PCS procedure codes on July 30 for treatment of patients with COVID-19, which went into effect on August 1, 2020. If not, please take a few minutes to review our colleague Rhonda Butler’s blog, posted on July 31.

The news sent us into high gear, contemplating how to operationalize the accurate capture of these codes. After talking, we took a collective deep breath and came to the following realizations:

First, a new code released outside of the traditional October 1 code implementation date is not normal. It's definitely a notable event that requires strategizing, especially by coding and clinical documentation integrity (CDI) professionals.

Second, the new ICD-10-PCS codes do not impact MS-DRG assignment, but will be used for data collection for research purposes. 

Every facility should also take a collective breath and prepare as follows:

• Understand the therapies represented by the new ICD-10-PCS codes
• Consider ways coding and CDI professionals can work together to identify evidence in the electronic health record (EHR) of the delivery of these therapies along with the route of administration (central v. peripheral vein). Ascertain how technology might assist in this process
• Determine whether your facility wants to code and report the new PCS codes
  

We want share what we have learned about the therapies the new codes represent:

New ICD-10-PCS codes

Remdesivir (Veklury®)

Manufacturer:  Gilead Sciences
Description: Broad-spectrum antiviral medication

Remdesivir is an experimental nucleotide which has shown to have potential activity against COVID-19.  The Food and Drug Administration (FDA) has authorized the emergency use of remdesivir to treat hospitalized patients with suspected or confirmed COVID-19.  Remdesivir is not approved anywhere globally for any use and the safety and efficacy for the treatment of COVID-19 are not proven. 

Currently, there are eight clinical trials in place to test the use of remdesivir in treating COVID-19 patients.

https://www.gilead.com/purpose/advancing-global-health/covid-19

https://www.gilead.com/purpose/advancing-global-health/covid-19/remdesivir-clinical-trials

Sarilumab (Kevzara®)

Manufacturer: Regeneron Pharmaceuticals and Sanofi
Description: Interleukin-6 inhibitor

Sarilumab originally received FDA approval for the treatment of rheumatoid arthritis in 2017.

The U.S. phase 3 clinical trial of the study of Kevzara in COVID-19 patients on a mechanical ventilator was stopped when it failed to show improvements in patients or failed to prevent death. 

https://emedicine.medscape.com/article/2500114-treatment#d14

https://www.fda.gov/news-events/press-announcements/coronavirus-covid-19-update-fda-continues-facilitate-development-treatments

Tocilizumab (Actemra®)

Manufacturer: Genentech
Description: Interleukin-6 inhibitor

Tocilizumab is prescribed to treat adults with rheumatoid arthritis or giant cell arteritis. It can also be used to treat children with polyarticular juvenile idiopathic arthritis or systemic juvenile idiopathic arthritis. 

It is currently being evaluated in several phase 3 clinical trials to determine the efficacy of using tocilizumab in hospitalized adult patients with pneumonia related to COVID-19.

https://emedicine.medscape.com/article/2500114-treatment#d14

Convalescent plasma

Convalescent plasma (also called immune plasma or hyperimmune plasma) is similar to fresh frozen plasma. The major difference from other plasma is that convalescent plasma is obtained from donors who have recovered from a specific infection – in this case, COVID-19. The hope is that convalescent plasma contains antibodies to COVID-19 at a level high enough to provide passive immunity to the recipient of the plasma.

Because COVID-19 convalescent plasma has not yet been approved for use by the FDA, it is regulated as an investigational product. The following pathways are available for administering or studying the use of COVID-19 convalescent plasma: clinical trials, expanded access or single patient emergency IND (investigational new drug).

https://www.fda.gov/emergency-preparedness-and-response/coronavirus-disease-2019-covid-19/donate-covid-19-plasma

https://www.fda.gov/vaccines-blood-biologics/investigational-new-drug-ind-or-device-exemption-ide-process-cber/recommendations-investigational-covid-19-convalescent-plasma

Identifying the application of these therapies

It will be key for coders to collaborate with CDI teams to capture the granular clinical detail around these COVID-19 therapies. A concurrent approach is important so that this information is surfaced before discharge, and coding and billing of the record is not delayed. The clinical documentation specialist (CDS) will most likely have reviewed the clinical care provided, especially since patients receiving these treatments are more complex cases and have longer lengths of stay.

Leveraging technology will help lighten the load for the CDS and coding professionals. Utilizing smart worklists to auto-populate and consolidate COVID-19 cases for easy identification on admission and through discharge ensures cases are not lost. Additionally, clinical artificial intelligence can identify the therapy and administration route, surfacing it as soon as it becomes part of the care plan. There are many ways technology can assist in ensuring this important information is captured completely and does not increase the drop bill time after discharge.

Finally, is it worth it to understand these therapies, surface them in the medical record and identify, code and report them?  We say yes! By identifying and coding these therapies, hospitals are not only collecting near real-time data that can contribute to national and global research, but the data can also be analyzed internally within the facility. This data can help hospitals understand and compare internal coded data with research published in medical journals and anecdotal knowledge about the therapies. For example, is length of stay shortened or patient outcomes improved with these therapies? Or is there increased risk of bleeding or decreased need for mechanical ventilation?

CDI and coding teams have standardized and refined their processes and procedures over many years, and incorporated technology as their programs have grown and matured. Although the CMS announcement may be viewed as a disruptive event, CDI and coding professionals are well-prepared to incorporate these new codes with relative ease. This pandemic has exposed many painful inadequacies within our healthcare delivery system---the clinical documentation improvement and coding process is not one of them.

Audrey Howard, RHIA, is a senior outsource services consultant with 3M Health Information Systems.

Julie Salomon, BSN, RN, is a 360 Encompass Chief Product Owner at 3M Health Information Systems.

Beth Wolf, MD, Medical Director, HIM for Roper St. Francis, 3M Physician Consultant.

Sue Belley, M.Ed., RHIA, CPHQ, is the manager of clinical content development and the manager of outsource services within the Consulting Services business of 3M Health Information Systems.

Click here to visit the 3M HIS COVID-19 resource page.

During a pandemic, healthcare information is gathered, studied, and published rapidly by scientists, epidemiologists and public health experts without the usual processes of review. Our understanding is rapidly evolving and what we understand today will change over time. Definitive studies will be published long after the fact. 3M Inside Angle bloggers share thoughts and expertise based on currently available information.