TN--Care Centers Management Consulting, Inc.

Document ID: CMS-2009-0035-0009
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: May 29 2009, at 11:45 AM Eastern Daylight Time
Date Posted: June 2 2009, at 12:00 AM Eastern Standard Time
Comment Start Date: May 12 2009, at 11:27 AM Eastern Standard Time
Comment Due Date: June 30 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 809bebb0
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Regarding Dehydration, on Page 22231-22232 of the rule it indicates, "Dehydration was dropped as a qualifier in any category, based on the American Medical Association's finding (see Faes, MC, ''Dehydration in Geriatrics,'' Geriatric Aging, 2007: 10(9): 590-596, available online at http://www.medscape.com/viewarticle/567678 that there is no standard definition of dehydration among providers, and that the signs and symptoms of dehydration may be vague and even absent in older adults. We believe that this qualifier is subject to a wide range of interpretation (and, therefore, is unreliable as a standard for RUG classification), as borne out by our MDS review, which showed instances of patients being coded for dehydration for long periods of time, that is, far beyond the time period in which we would expect the issue to be resolved through treatment. Thus, we believe continuing to use dehydration as a qualifier could result in inaccuracy in RUG classification. (This is not to minimize the potentially serious nature of dehydration and the need for prompt medical attention in some cases, but rather to improve coding accuracy)." However, in the Special Care category, Dehydration remains a qualifire for that category in combination with Fever. The comments in the proposed rule noted above appear to indicate that dehydration as a qualifier has been removed from "any" category. This would seem to imply that dehydration, even in combination with fever, would not contribute as a qualifying elemeny to any RUG classification. Given the information noted in the proposed rule above related to dehydration , Is it CMS's intention to leave Dehydration a qualifier in Special Care high, in combination with fever? If CMS' intention is to leave dehydration with fever a qualifier then it seems there needs to be some clarification in the statement about dehydration noted above. Perhaps the final rule might clarify this issue by indicating that, "dehydration alone as a unique qualifier has been dropped, but remains as a combined qualifier with fever in the Special Care High category". The reference in the proposed rule in relation to dehydration, that it was, "dropped as a qualifier in any category", and that, "there is no standard definition of dehydration among providers, etc." is confusing when dehydration remains as any part of even the combined qualifying element as it does in Special Care High.

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