MDS 2.0 Deep Tissue Injury Coding & ulcer coding

At last week's SNF ODF, CMS discussed the following:

On the MDS 2.0--currently there is NO WAY TO DOCUMENT AN UNSTAGEABLE PRESSURE ULCER (unless it has eschar) OR A SUSPECTED DEEP TISSUE INJURY (POTENTIAL ULCER). CMS staff clarified the proper coding for MDS 2.0 item M1, and answered 2 questions on this topic--the answer is do not code these SDTI at M1. Follow the RAI Manual guidelines--what is observed in the past 7 days per the RAI Manual definitions for each stage. Accurate skin assessment on admission (or at any point in time), as documented on facility skin records, will show the status/progression of an SDTI or unstageable "ulcer". Right now, there is no "penalty" attached to an ulcer which shows up on a subsequent MDS--it goes into the overall prevalence rate for the QM. Nor is there currently a way for CMS to ascertain if an ulcer was present on admission, or if it occurred "in-house." (A recent informal AHCA Clinical Practice Committee survey demonstrated this inconsistency--staff had been documenting Suspected Deep Tissue Injury in different ways. Facilities might code a SDTI as either a Stage 1 or a Stage 4--or NOT code.) This is a serious concern--if a SDTI is coded as a stage 4, the facility may be eligible for a higher PPS RUG rate based on this coding. Code per the RAI MANUAL guidelines.

Also on this topic--

Effective October 1, 2008, the ICD9CM codes will be updated. As part of this update, there are new codes for different ulcer stages, including suspected deep tissue injury and unstageable. The update can be found at:

http://www.cdc.gov/nchs/datawh/ftpserv/ftpicd9/ftpicd9.htm#guidelines

For clarity, SDTI can be coded on the MDS 2.0 at I3, and on the billing UB.