CMS to Feature ICD-10 Codes on its CMS-2728 End Stage Renal Disease Patient Registration Form

On July 31, 2014, the Centers for Medicare & Medicaid Services (CMS) formally announced that the U.S. Department of Health and Human Services (HHS) had finalized Oct. 1, 2015 as the new compliance date for healthcare providers, health plans, and healthcare clearinghouses to ICD-10.

At that time, all entities covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) must transition to this new set of codes for electronic healthcare transactions. In support of this change and to help ensure that all Medicare-certified dialysis facilities and transplantation centers throughout the United States and U.S. territories have the codes needed when reporting patient data, CMS updated a form used by these facilities — it’s known as the CMS-2728 Medicare Entitlement and/or Patient Registration form — to reflect the new diagnosis codes for “primary cause of renal failure.”

Medicare-certified dialysis facilities complete CMS-2728 forms for individuals with end-stage renal disease (ESRD). These forms and additional patient and administrative data are securely processed by facilities through CMS’s CROWNWeb data collection system. In addition to updating the CMS-2728 form, CMS implemented changes to CROWNWeb’s infrastructure to automatically convert processes over to ICD-10 once October 2015 arrives.

What Is The CMS-2728 Form?

The CMS-2728 form serves as a medical evidence report for all ESRD patients who are dialyzing at a Medicare-certified dialysis or transplantation facility in the U.S. or a U.S. territory. These forms are used to help determine if an individual is entitled to Medicare under the end-stage renal disease provisions of the law. There are three versions of the CMS-2728 form — including an Initial, supplemental, and re-entitlement CMS-2728 form — that could be completed by facilities during the course of a patient’s treatment.

The forms capture details specific to the cause of the patient’s renal failure and the treatment to be provided by the dialysis or transplantation center. Information captured as part of CMS-2728 forms includes, but is not limited to:

• Primary cause of renal failure
• Co-morbid conditions
• Laboratory values within 45 days of the most recent ESRD episode
• Date regular chronic dialysis began
• Current status of transplant

Facilities submit signed and completed CMS-2728 forms directly to CMS using the aforementioned CROWNWeb system, maintain copies with patients’ files, and mail original forms to the Social Security Administration (SSA) if the patient is applying for ESRD Medicare benefits.

When completing the CMS-2728 form for patients, the attending physician indicates the primary cause of renal failure based on the currently used ICD codes. The form has boasted the clinically modified version of the ninth revision of the ICD codes (ICD-9-CM) for many years. Go online to http://www.cms.gov/Medicare/CMS-Forms/CMS-Forms/downloads/cms2728.pdf for further details on the CMS-2728 form.

What is CROWNWeb?

CROWNWeb is a secure, Web-based system that captures clinical and administrative data from more than 6,000 dialysis facilities and approximately 30 kidney transplantation centers across the country. The system replaced a historic paper-based data collection process used by facilities for decades prior. The new system was launched in June 2012 and since then it has provided the renal community with a continuous method of accessing and reporting patient-based data.

ICD-9 to ICD-10: Why the Transition?

Periodically, the World Health Organization (WHO) revises the ICD code sets to help ensure that they reflect changes in the medical and healthcare fields. Furthermore, with approval from WHO, the United States developed Clinical Modification (CM) and Procedure Coding System (PCS) updates used to provide additional details for medical diagnoses and inpatient procedures.

The U.S. has been using the clinically modified version of the ninth revision of ICD (ICD-9-CM) since 1979. The U.S. has required ICD-9-CM codes for Medicare and Medicaid claims for more than 30 years, and according to the Centers for Disease Control and Prevention (CDC), the content of ICD-9-CM is no longer clinically appropriate, because it features limited data about patients’ medical conditions and hospital inpatient procedures. Simply put, the number of available codes is limited and the coding structure is too restrictive.

ICD-10 was endorsed by the 43rd World Health Assembly in May 1990 and came into use in WHO member states as of 1994. Since 1994, more than 26 countries — including Canada, Costa Rica, Germany, China, and Australia — have started using ICD-10 codes. Currently, the U.S. is the only industrialized nation still utilizing ICD-9-CM codes for morbidity data. However, the U.S. did implement ICD-10 for mortality coding and classification in 1999.

Benefits of Implementing ICD-10

ICD-10 codes provide more detailed diagnoses and procedures compared to those of ICD-9-CM. ICD-10 uses alphanumeric categories that feature nearly 19 times as many procedure codes as ICD-9-CM (going from approximately 3,824 to nearly 71,924) and nearly five times as many diagnosis codes (going from 14,025 to 69,823). According to the CDC, by enabling more detailed patient history coding, ICD-10 can help to better coordinate a patient’s care across providers and over time. Furthermore, in a July 31, 2014, announcement, CMS Administrator Marilyn Tavenner said that “ICD-10 codes will provide better support for patient care, and improve disease management, quality measurement and analytics. For patients under the care of multiple providers, ICD-10 can help promote care coordination.”

Additionally, according to CMS, by using ICD-10 doctors can capture much more information, resulting in a better understanding of important details about patient health than with ICD-9-CM.

ICD-10 in CROWNWeb

Providers should keep track of all timelines, conversion details, training expectations, and more information provided by CMS online at http://www.cms.gov/ICD10 to help ensure that all facility representatives are informed of these pending changes. When attempting to complete the CMS-2728 form on or after Oct. 1, 2015, users will notice a drastic increase in the number of selections in CROWNWeb. CROWNWeb will recognize ICD-10 code entries for all transactions processed beginning with that transition date.

For More Information

For more information about the transition from ICD-9-CM to ICD-10 codes, again, go online to http://www.cms.gov/ICD10. There, users can access the latest news, updates, resources, statutes, and regulations. For more information about CROWNWeb and the ICD-10 selections on the CMS-2728 form, visit the Project CROWNWeb website at www.projectcrownweb.com.

About the Author

Oniel Delva is the Communications and Training Manager for the Florida End Stage Renal Disease Network in Tampa, Fla.

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