MCN Healthcare: Policy Management and Compliance Tools

This week the Centers for Disease Control and Prevention (CDC) released results of its Dialysis Bloodstream Infection Prevention Collaborative showing a 32 percent decrease in overall bloodstream infections and a 54 percent decrease in vascular access-related bloodstream infections after CDC prevention guidelines were used.

Vascular access-related bloodstream infections are those related to devices used to access the bloodstream for hemodialysis. With approximately 37,000 bloodstream infections occurring each year among dialysis patients with central lines, at an estimated cost of $23,000 per hospitalization, the CDC believes that wider implementation of the practices in this study could help save lives and reduce excess health care spending.

In April 2009, the CDC launched a collaborative project to prevent bloodstream infections among dialysis patients and invited outpatient dialysis centers to participate. CDC and the participating dialysis centers worked together to develop and implement the package of interventions to prevent bloodstream infections.

Core interventions:

• Surveillance and feedback using National Healthcare Safety Network
• Performing hand hygiene observations
• Performing catheter/vascular access care observations
• Conducting staff education and competency
• Patient education/engagement
• Catheter use reduction
• Use of Chlorhexidine for skin antisepsis
• Appropriate antiseptic for catheter hub disinfection
• Antimicrobial ointment application to catheter exit sites during dressing change

Dialysis facilities can implement many of CDC's recommendations by using a series of checklists and performing observations using audit tools that are currently available on CDC's website. Additionally, CDC has released a free infection prevention course for dialysis nurses and technicians that reviews CDC recommended practices in a convenient, 1-hour self-guided internet training course that also offers continuing education credits.

Preventing bloodstream infections among dialysis patients has been identified as a national priority by the U.S. Department of Health and Human Services. According to the CDC, several initiatives have demonstrated the ability to reduce bloodstream infections in hospital intensive care units, but prior to the CDC Dialysis Bloodstream Infection Prevention Collaborative, there have been few similar initiatives attempted in outpatient settings.

Included with today's notice are policies and procedures related to the CDC core interventions to prevent bloodstream infections.

This week The Joint Commission (TJC) issued a clarification for LD.04.03.11, also known as the "patient flow "standard. 

A note to LD.04.03.11, EP 6 (which goes into effect January 1, 2014) TJC states that, in the interest of patient safety, recommended boarding timeframes in the emergency department should not exceed 4 hours.

TJC is now clarifying that it uses notes to provide guidance and additional information about an element of performance and therefore, recommendations offered within notes are not scored.  The 4 hour time frame referred to in this note is not a requirement for Joint Commission accreditation.

TJC understands that specific boarding times will fluctuate depending on the organization and the note to LD.04.03.11 EP 6 is offered only as guidance.  Follow the link below for more information.

Included with today's notice are two example policies and procedures related to managing patient flow.

As StayAlert has reviewed previously, on October 1, 2014, the health care industry will transition from ICD-9 to ICD-10 codes for diagnoses and inpatient procedures.   This transition is going to change how health care providers, including medical practices, do business, from registration and referrals to superbills and software upgrades.

CMS has identified several steps that medical practices should be taking to ensure a smooth transition to ICD-10:

• Identify current systems and work processes that use ICD-9 codes. This could include clinical documentation, encounter forms/superbills, practice management system, electronic health record system, contracts, and public health and quality reporting protocols. It is likely that wherever ICD-9 codes now appear, ICD-10 codes will take their place.
• Talk with your practice management system vendor about accommodations for ICD-10 codes. Confirm with your vendor that your system has been upgraded to Version 5010 standards, which have been required since January 1, 2012. Unlike the older Version 4010/4010A standards, Version 5010 accommodates ICD-10 codes.
• Contact your vendor and ask what updates they are planning to make to your practice management system for ICD-10, and when they expect to have it ready to install. 
• Check your contract to see if upgrades are included as part of your agreement.
• If you are in the process of making a practice management or related system purchase, ask if it is ICD-10 ready.
• Discuss implementation plans with all your clearinghouses, billing services, and payers to ensure a smooth transition. Be proactive, don't wait. Contact organizations you conduct business with such as your payers, clearinghouse, or billing service. Ask about their plans for ICD-10 compliance and when they will be ready to test their systems for the transition.
• Talk with your payers about how ICD-10 implementation might affect your contracts. Because ICD-10 codes are much more specific than ICD-9 codes, payers may modify terms of contracts, payment schedules, or reimbursement.
• Identify potential changes to work flow and business processes. Consider changes to existing processes including clinical documentation, encounter forms, and quality and public health reporting.
• Assess staff training needs. Identify the staff in your office who code, or have a need to know the new codes. There are a wide variety of training opportunities and materials available through professional associations, online courses, webinars, and onsite training. If you have a small practice, think about teaming up with other local providers. For example, you might be able to provide training for a staff person from one practice, who can in turn train staff members in other practices. Coding professionals recommend that training take place approximately six months prior to the ICD-10 compliance deadline.
• Budget for time and costs related to ICD-10 implementation, including expenses for system changes, resource materials, and training. Assess the costs of any necessary software updates, reprinting of superbills, trainings, and related expenses.
• Conduct test transactions using ICD-10 codes with your payers and clearinghouses. Testing is critical. You will need to test claims containing ICD-10 codes to make sure they are being successfully transmitted and received by your payers and billing service or clearinghouse. Check to see when they will begin testing, and the test days they have scheduled

At this stage in the implementation process the following should be occurring:

• High-level training on ICD-10 for clinicians and coders to prepare for testing (e.g., clinical documentation, software updates)
• Initial testing of ICD-10 codes and systems with your practice's coding, billing, and clinical staff: Use ICD-10 codes for diagnoses your practice sees most often; Test data and reports for accuracy
• Monitor vendor and payer preparedness, identify and address gaps.

Key Upcoming Dates:

• October 1, 2013: Begin testing claims and other transactions using ICD-10 codes with business trading partners such as payers, clearinghouses, and billing services
• January 1, 2014 - April 1, 2014: Review coder and clinician preparation; begin detailed ICD-10 coding training.

Visit the CMS ICD-10 for the latest news and resources.