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.
TN--Care Centers Management Consulting, Inc.
This is comment on Proposed Rule
Medicare Program: Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities for FY 2010, etc.
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