CMS Issues Alert on ICD-9 and ICD-10 Exclusions
Heather Sanderson
May 25, 2016

The Centers for Medicare and Medicaid Services (CMS) released a technical alert dated May 23, 2016 related to Non-Group Health Plan (NGHP) MMSEA Section 111 reporting. This alert communicates that there are newly excluded ICD diagnosis codes that will no longer be accepted by CMS beginning on January 7, 2017.  The exclusion includes codes from both the ICD-9 and ICD-10 revisions as follows: 

·         ICD-9-CM
o   999.9 (Other and unspecified complications of medical care, not elsewhere classified)
 
·         ICD-10-CM
o   T88.7XXA (Unspecified adverse effect of drug or medicament, initial encounter)
o   T88.7XXD (Unspecified adverse effect of drug or medicament, subsequent encounter)
o   T88.7XXS (Unspecified adverse effect of drug or medicament, sequela)
o   T88.8XXA (Other specified complications of surgical and medical care, not elsewhere classified, initial encounter)
o   T88.8XXD (Other specified complications of surgical and medical care, not elsewhere classified, subsequent encounter)
o   T88.8XXS (Other specified complications of surgical and medical care, not elsewhere classified, sequela)
o   T88.9XXA (Complication of surgical and medical care, unspecified, initial encounter)
o   T88.9XXD (Complication of surgical and medical care, unspecified, subsequent encounter)
o   T88.9XXS (Complication of surgical and medical care, unspecified, sequela)
 
While CMS will continue to accept these codes on claims submitted before January 2, 2017, it is important to note that they will cause an SP disposition code with an error attached to the ICD position in which they were reported after that date. Errors will also be returned on claims that were previously submitted and accepted by CMS with these ICD codes if an update is submitted to CMS on or after January 2, 2017.
 
Franco Signor advises responsible reporting entities (RREs) phase out their use of these newly excluded ICD codes now to prepare for current and future submission to CMS. Any update to CMS of a claim, such as termination of ongoing responsibility for medicals, total payment obligations to claimant, or other updates, will need to have the excluded codes removed if the update is submitted on or after January 2, 2017 in order for CMS to accept the update without errors.
 
CMS will integrate the changes found in this alert into a forthcoming update of the NGHP User Guide, which is currently on version 4.9.              
 
 
 
Heather Schwartz Sanderson, Esq., MSCC, CHPE, CLMP, CMSP
Chief Legal Officer
Franco Signor LLC