CMS Updates: Kennedy Terminal Ulcer, Mucosal Pressure Ulcers, and Revised IRF-PAI

The Centers for Medicare and Medicaid Services (CMS) has recently issued some changes regarding pressure ulcer (PrU) documentation in several care settings. For the first time, the CMS has provided guidance regarding the Kennedy Terminal Ulcer. As stated in the draft May 2013 Version 2.0 of the CMS long-term care hospitals (LTCH) quality reporting program manual chapter 3 section M page M-3: "Skin ulcers that develop in patients who have terminal illness or are at the end of life should be assessed and staged as pressure ulcers until it is determined that the ulcer is part of the dying process (also known as Kennedy ulcers). When an ulcer has been determined to be a Kennedy ulcer, it should not be coded as a pressure ulcer" (http://http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/LTCH-Quality-Reporting). At this time, this is only applicable to LTCH.

Based on the understanding that mucosal PrUs cannot be staged because anatomical tissue comparisons cannot be made, CMS directs that in LTCH, mucosal ulcers should not be coded on the LTCH CARE Data Set (http://http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/LTCH-Quality-Reporting/). In long-term care (LTC), these ulcers are not coded in section M for PrUs, but rather in a different section for abnormal mouth tissue for oral mucosal ulcers (http://http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/NursingHomeQualityInits/MDS30RAIManual.html).

For inpatient rehabilitation facilities (IRF), CMS has issued the draft of the IRF-Patient Assessment Instruments Version 1.2 (http://http://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/InpatientRehabFacPPS/IRFPAI.html), which will become effective October 1, 2014. Current questions 48, 49, and 50 (one quarter of a page) are completely revised and replaced with 3.5 pages. More important, this represents the first time that 3 care settings (LTC, LTCH, and IRF) will have consistent numbers and items for PrU reporting. Other care settings may want to take notice of what PrU documentation CMS is requiring.