• Definition
  • Hospital Acquired Infections
• Implementation
• Coding
• State Reporting
• Federal Reporting
• CMS Pub 100-04 Medicare Claims Processing, Transmittal 1240 , Date: MAY 11, 2007
• POA Guidelines (September 2006)
• Exemptions to POA Reporting
• Articles:
  • Recommendations to the Cooperating Parties
  • HCUP - The Case for the Present-on-Admission (POA) Indicator Report# 2006-01
     

Addition of Present on Admission Code
The Hospital-Acquired Conditions (HAC) and Present on Admission (POA) Indicator provision was authorized under Section 5001(c) of the Deficit Reduction Act (DRA).

For discharges occurring on or after October 1, 2008, hospitals will not receive additional payment for cases in which one of the selected conditions was not present on admission. That is, the case would be paid as though the secondary diagnosis was not present. Section 5001(c) provides that CMS can revise the list of conditions from time to time, as long as it contains at least two conditions.

Section 5001(c) also requires hospitals to report present on admission information for both primary and secondary diagnoses when submitting payment information for discharges on or after October 1, 2007.

CMS has titled this statutory implementation Hospital Acquired-Conditions (HAC) and Present on Admission (POA) Indicator.

The Present on Admission ICD-9-CM Coding Guidelines were released recently and are available on the CDC’s National Center for Health Statistics web site (click here).

Implementation
Implementation of these guidelines will require hospitals to not only change their medical record information systems, but also requires that clinicians are provided with educational information on these changes so they may properly record occurrences. Hospitals need to provide ongoing training and support so that one can understand the importance of documenting those occurrences prior to or during admission, and for some select cases, those in which a determination cannot be clinically determined (i.e. Some infections).

State Reporting Requirements
The State of Kentucky is moving ahead to collect the Present on Admission codes on the hospital discharge data starting in mid-2007. The proposed rules presented to the State Board of Health will have a target date of January 1, 2008 with a phase in starting July 1, 2007.

KHA is working collaboratively with the Kentucky Department of Public Health (KDPH) and will soon be releasing the new reporting formats that will be used in transmitting data to KHA and then on to KDPH. KHA will allow hospitals to begin submitting data starting July 1, 2007 using the new formats which include the Present on Admission code.

Federal Requirements and Challenges

The Present on Admission (POA) Indicator requirement and Hospital-Acquired Conditions (HAC) payment provision only apply to Inpatient Prospective Payment Systems (IPPS) Hospitals.

At this time, the following hospitals are EXEMPT from the POA Indicator and HAC:

1. Critical Access Hospitals (CAHs)

2. Long-term Care Hospitals (LTCHs)

3. Maryland Waiver Hospitals

4. Cancer Hospitals

5. Children's Inpatient Facilities

The federal government has a major technical challenge in collecting the Present on Admission code on the current HIPAA 837 format (known as the 4010 A1 version) as there is no physical location for this code in the 4010 A1 format. As there is a national standard for staging in of HIPAA formats, the HIPAA 5010 version which includes the Present on Admission codes is not scheduled to be implemented by providers until 2012 (under the HIT reconciliation bill under consideration it has a change calling for the implementation date of Version 5010 to be 2009).

Currently the Medicare administrators are meeting on this issue to determine how best to incorporate the Present on Admission codes into the current HIPAA 837 format. There is no easy solution as all of the approaches discussed have some implementation challenges for both providers and health plans.