October 1, 2015 came and went. The sky didn’t fall, but many agencies did stumble as they grappled with software glitches, struggled with insufficient documentation from referral partners and from their own clinicians, and as internal coding-knowledge gaps surfaced. Agencies also continue to receive conflicting and/or inapplicable guidance from the American Hospital Association’s (AHA) Coding Clinic, CMS’ designee for official ICD coding guidance and clarifications. These inconsistencies can lead to payment delays or claim denials.

Confusion over the use of ‘A’ as the seventh character indicating initial encounter by home health agencies brought the problem to light. In light of the issue, the Home Health and Hospice ICD-10 Transition Workgroup (the “ICD-10 Transition Workgroup”), of which the Alliance is a member, worked with CMS to ensure that the January 1, 2016 release of the home health Grouper reflected the AHA Coding Clinic’s guidance around use of the seventh character A. But this instance is by no means the only time when new guidance has caused confusion for the industry.

Numerous instances of guidance issued by the AHA Coding Clinic are not easily interpreted by or adapted to home health or hospice. The ICD-10 Transition Workgroup is working closely with the AHA Coding Clinic to address this concern. We have crafted a solution that we believe will ensure that guidance issued by the AHA Coding Clinic does not unintentionally lead to improper coding or create barriers to payment for home health or hospice.

Working on behalf of industry, the ICD-10 Transition Workgroup has developed an agreement with the AHA Coding Clinic. The AHA Coding Clinic has agreed to accept industry queries from the board of the Association of Home Care Coding & Compliance (AHCC) and the board of its credentialing body, the Board of Medical Specialty Coding & Compliance (BMSC), on behalf of the industry. As the BMSC board is comprised of eight of the nation’s leading home health and hospice coding experts, the AHA Coding Clinic has further agreed to accept with those queries a recommended response and the rationale for that response. The AHA Coding Clinic Editorial Advisory Board will consider the query as well as the recommended response before issuing guidance.

Coding questions should be submitted to AHCC using the following email: AHCCVoice@decisionhealth.com. BMSC board members will review the questions submitted to determine if there already is an answer to the question or if there is a need for clarification or additional guidance from the AHA Coding Clinic. If there is an answer, the board will point you to where that answer can be found. If the board believes guidance or clarification is needed, the query will be forwarded to the AHA Coding Clinic with the board members’ recommended response and rationale. Subsequent guidance issued by the Coding Clinic’s EAB will be distributed to the industry through a communique from your association.

By funneling all home health and hospice industry coding questions through one channel and disseminating resulting guidance or clarification throughout the industry at one time, we will be able to accomplish several significant goals:

  • Identify and resolve widespread coding issues affecting all agencies
  • Receive from the AHA Coding Clinic one response that applies to all agencies
  • Identify industry-wide knowledge gaps
  • Ensure correct and compliant coding based on first-hand knowledge of changing guidance

To our knowledge, the AHA Coding Clinic Editorial Advisory Board never has considered provider setting when issuing coding guidance. Now they will. This is an important step in ensuring that home health and hospice have the tools they need to correctly and compliantly code and submit claims.

About AHCC

AHCC is the community for professionals dedicated to providing quality care in post-acute care settings and establishing, meeting, and maintaining standards of excellence in their area of expertise.

AHCC’s credentialing arm, the Board of Medical Specialty Coding & Compliance (BMSC), offers professional credentials, including the only nationally accredited home health coding credential that tests coding skills exclusively, the Home Care Coding Specialist—Diagnosis (HCS-D), and the nationally accredited Home Care Clinical Specialist – OASIS (HCS-O).

BMSC has been credentialing home health coders since 2003. More than 63% of agencies require coders to have earned the HCS-D credential as a condition of employment. The credentials are overseen by an independent board of home health and OASIS experts nationally recognized as leading authorities. Each board member has more than 25 years of experience in home health and hospice, and all are in-demand home health and hospice coding educators.

*Home Health and Hospice ICD-10 Transition Workgroup

Alliance for Home Health Quality & Innovation

Teresa Lee, Executive Director


Association of Home Care Coding & Compliance

Corinne Kuypers-Denlinger, Executive Director; VP, Post-Acute Care Product Group, DecisionHealth

Tricia A. Twombly, CEO, BMCS; Senior Director, DecisionHealth


Centers for Medicare & Medicaid Services

Dr. William Rogers, ICD-10 Ombudsman


National Association for Home Care & Hospice

Mark K. Carr, VP, Regulatory Affairs

Theresa Forrester, VP, Hospice Policy & Programs


National Hospice & Palliative Care Organization

Jennifer Kennedy, Director, Regulatory & Compliance


Visiting Nurses Association of America

Liza Greenberg, VP, Quality (Interim)

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