Rinkle, Valerie

Hospitals include charges and ICD9 procedure codes for nondiagnostic services occurring on the same day or before midnight when a patient is admitted directly from a department of the hospital as an inpatient because this is one encounter and there is not a separate medical record to make a determination of a principal diagnosis for the preadmission service. The concept of principal diagnosis does not apply to this outpatient portion of the encounter, rather the concept of admitting diagnosis applies. Hospitals and FIs and QIOs have all interpreted this provision to apply to preadmission services provided in an encounter separate from the encounter resulting in the inpatient admission to the hospital. Countless claims have been audited by these contractors over more than two decades and deemed to be correct until now when a RAC has made a new interpretation. Requiring hospitals to separate a medical record based on the time of the inpatient admission order, code services documented prior to that clock time and somehow derive a legitimate principal diagnosis from that coded for the inpatient stay will be operationally burdensome. Furthermore, if hospitals choose to separately bill Part B for these services, beneficiaries will experience significantly increase co-payments in addition to their inpatient deductible and it will appear the hospital has billed twice for a single encounter. This will result in significantly strained patient relations. The charges used to set MS-DRG weights will also be impacted in the future. I am also concerned about patient safety with the way EHRs work. Please reconsider this issue.