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CMS-HCC Risk Adjustment Alert!
There has been significant and sustained increase in medical record requests to providers from Medicare Advantage (MA) insurers for risk adjustment, aimed at finding additional diagnoses to reflect higher patient "sickness" scores and maximize payments. This practice, often labeled as "chart review" or "chart harvesting," has led to accusations by oversight organizations such as the Office of the Inspector General (OIG) of MA insurers artificially inflating risk scores and, consequently, Medicare payments.
HCC Risk Adjustment is a statistical method used by CMS to adjust capitated payments to MA plans based on the health status and demographic factors (age, sex, etc.) of enrollees. It was designed to predict future healthcare costs, paying more for sicker patients to encourage care access, and was created as a way to help make sure doctors and other health providers are paid fairly for the people they treat by using the CMS-Hierarchical Condition Category (CMS-HCC) model to assign a risk score.
This risk adjustment model was never intended to be used in a way that inflates Medicare payments to MA plans. Oversight organizations such as the OIG are aware of payer noncompliance, as evidenced by reports published across multiple insurance carriers. One such report estimates that Priority Health received at least $4.4 million in net overpayments for 2018 and 2019 due to noncompliance with federal requirements.
The IMA has received inquiries from clinics regarding MA plans requesting different diagnosis codes than what seems appropriate. For example, one clinic received commonly missed HCC codes under "Medications for any patient on chronic: F11.XXX-Opioid use, dependence, or abuse; F13-20 - Anxiolytics, or sedatives (sleep meds); and F15.20-Stimulants (ADHD)." For a patient on long term (current) opioid management, the proper diagnosis is reported with Z79.891 as a medical treatment by a medical provider and not reported as F11.XXX-Opioid use, dependence, or abuse as a behavioral and mental health disorder. Per ICD10 guidelines, "Assign a code from Z79- if the patient is receiving a medication for an extended period as a prophylactic measure or as treatment of a chronic condition or a disease requiring a lengthy course of treatment." Codes in category Z79- are not used "for patients who have addictions to drugs." Similarly, patients on other long term medication management they listed would not be reported as sedative-dependent or stimulant-dependent as these are mental and behavioral health disorders.
We advise clinics to base their coding on the ICD10 guidelines and not to inflate them or misreport based on pressures from Medicare Advantage plans. Some of this pressure not only up-codes diagnoses, but it also labels patients with conditions that were not diagnosed by a provider and do not follow the appropriate ICD10 guidelines for reporting. We urge providers to follow all CMS, AMA, and ICD10 guidelines. Below are some basic ICD10 rules for appropriate diagnosis coding. When in doubt, please reach out to the IMA for guidance.
Diagnoses code selection:
- Should be based on diagnoses managed and documented
- Should be coded to the highest specificity
- Should not be pulled from an active problem list, unless it is being addressed with history, exam, A/P, or indicated in the decision making
- Should include all documented conditions that coexist at the time of the encounter and require management or affect patient care.
- Should not include conditions that were previously treated and no longer exist
For more information, see:
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