CMS FY 2011 Proposed Rule: Acute renal failure demoted to CC status

From CMS: Proposed Rule FY 2011:

(4) Proposed Change to the Severity Level for Acute Renal Failure, Unspecified
Diagnosis Code

We received a request to reclassify diagnosis code 584.9 (Acute renal failure,unspecified) from a MCC to a CC. The commenter stated that this code is being widely used to capture degrees of renal failure that range from that which is caused by mild dehydration with only minor laboratory abnormalities all the way through severe renal failure that requires dialysis. The commenter pointed out that there are no clinical criteria for assigning diagnosis code 584.9 (Acute renal failure, unspecified). The attending
physician must simply document the presence of acute renal failure for the diagnosis code to be assigned. The concern is that the diagnosis code for Acute renal failure,unspecified (diagnosis code 584.9) is being assigned to patients with a low clinical severity level.

We also point out that the Editorial Advisory Board of Coding Clinic for ICD-9-CM has received a number of requests to clarify the use of diagnosis code 584.9. Coders are observing the terminology of “acute renal failure” being applied to patients
who are simply dehydrated. These patients do not require renal dialysis, and they do not appear to be severely ill. Coders have stated that there appears to be an increase in the use of the terminology of acute renal failure for patients who were previously referred to as acute renal insufficiency. When acute renal insufficiency is documented, the ICD-9-CM index directs the use of code 593.9 (Unspecified disorder of kidney and ureter). Diagnosis code 593.9 includes acute renal insufficiency and is classified as a
non-CC. The problem is further compounded by the fact that there is no consistent convention among clinicians for documenting acute renal insufficiency versus acute renal failure.

Additional information and the methodology used for this decision begins on page 212 of the document.

Link to the complete Proposed Rule:

http://www.federalregister.gov/OFRUpload/OFRData/2010-09163_PI.pdf
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