Department of Health and Human Services 
OFFICE OF 
INSPECTOR GENERAL 
Medicare Payments for Septicemia 
JUNE GIBBS BROWN 
Inspector General 
MARCH 1999 
OEI-03-98-00370  OFFICE OF INSPECTOR GENERAL 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, is to 
protect the integrity of the Department of Health and Human Services programs as well as the 
health and welfare of beneficiaries served by them.  This statutory mission is carried out through a 
nationwide program of audits, investigations, inspections, sanctions, and fraud alerts.  The 
Inspector General informs the Secretary of program and management problems and recommends 
legislative, regulatory, and operational approaches to correct them. 
Office of Evaluation and Inspections 
The Office of Evaluation and Inspections (OEI) is one of several components of the Office of 
Inspector General.  It conducts short-term management and program evaluations (called 
inspections) that focus on issues of concern to the Department, the Congress, and the public.  The 
inspection reports provide findings and recommendations on the efficiency, vulnerability, and 
effectiveness of departmental programs. 
OEI's Philadelphia office prepared this report under the direction of Robert A. Vito, Regional 
Inspector General, and Linda M. Ragone, Deputy Regional Inspector General.  Principal OEI 
staff included: 
REGION  HEADQUARTERS 
David Graf, Project Leader	 Tricia Davis, Program Specialist 
Mark Krushat, Research and Special Projects 
To obtain copies of this report, please call the Philadelphia Regional Office at (800) 531-9562. 
Reports are also available on the World Wide Web at our home page address: 
http://www.dhhs.gov/progorg/oei  E X E C U T I V E  S U M M A R Y

PURPOSE 
To identify hospitals with atypically high billing patterns for patients with septicemia (DRG 416). 
BACKGROUND 
Under Medicares PPS reimbursement formula, the payment a hospital receives is based upon the 
individual hospitals payment rate and the weight of the DRG to which a case is assigned.  A 
DRGs weight represents the average resources needed for cases in that classification relative to 
the average resources needed for cases in all DRGs.  The higher the relative weight, the greater 
the reimbursement. 
DRG 416 represents septicemia (blood poisoning).  Generally, the DRG payment for septicemia is 
dependent on the principal diagnosis code.  Twenty-four diagnosis codes can result in a discharge 
grouping of DRG 416.  This code typically triggers a higher Medicare reimbursement compared 
to other diagnostic codes with similar symptoms.  DRG 320, kidney and urinary tract infections, is 
one such code. 
The Health Care Financing Administration (HCFA) contracts with two Clinical Data Abstraction 
Centers to collect clinical data from hospital medical records.  A part of the Abstraction Centers 
responsibility is the validation of a national random sample of claims from all Medicare inpatient 
hospital discharges.  The results of the 1996 validation effort showed that approximately 13 
percent of the sample DRG 416 discharges should have been coded to a lower weighted DRG. 
HCFA estimated that the total overpayment attributable to incorrect DRG 416 classifications was 
$48,930,882. 
Our office recently conducted DRG validation work on a sample of 2,622 Medicare inpatient 
hospital discharges from 1996.  The results of this validation showed that approximately 20 
percent of the sample DRG 416 discharges were improperly coded. 
We analyzed the Medicare Provider Analysis and Review file, for fiscal years 1993 to 1996, to 
identify hospitals with atypically high billings for DRG 416. 
FINDINGS 
A small number of hospitals have atypically high Medicare billings for DRG 416. 
A relatively small number of hospitals had abnormally high DRG 416 discharges compared to 
national figures.  For 120 hospitals (out of  4,701) identified in our review, DRG 416 discharges 
increased from 4,583 in 1993 to 13,450 in 1996 -- an almost three-fold increase.  Nationally, 
DRG 416 discharges increased from 167,900 in 1993 to 220,441 in 1996. 
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i  The proportion of DRG 416 discharges to total discharges increased by a factor of almost 3, from 
1.57 percent in 1993 to 4.33 percent in 1996.  Nationally, this same proportion increased from 
1.51 percent in 1993 to 1.88 percent in 1996. 
Previous DRG validation reviews showed that a substantial number of improperly coded DRG 
416 discharges should have been coded as DRG 320.  For the 120 hospitals, DRG 320 discharges 
decreased from 6,330 in 1993 to 4,792 in 1996.  Nationally, DRG 320 discharges increased from 
172,659 in 1993 to 177,042 in 1996. 
The inappropriate billing of DRG 416 could have a major financial impact. 
From the previous DRG validation work performed by our office, we found an average per 
discharge difference of $2,254 between DRG 416 and the DRG we believe should have been 
coded.  For the 120 hospitals, the number of DRG 416 discharges exceeded national norms by 
approximately 7,345 cases.  Using the $2,254 per discharge difference from our previous work, 
we estimate that potential overpayments could be as high as $16.6 million. 
The true upcoding error rate can only be determined by undertaking a detailed claims review at 
each hospital.  Therefore, the potential overpayments at each hospital will vary according to 
applicable coding error rates. 
RECOMMENDATION 
We recommend that HCFA institute a system to identify hospitals with atypically high billings for 
DRGs identified by the Clinical Data Abstraction Centers as having a high potential for being 
upcoded.  Once the hospitals have been identified, a review of the discharges should be made. 
We have referred the 120 hospitals that we have identified as having atypically high growth in 
DRG 416 discharges to our Office of Investigations. 
AGENCY COMMENTS 
The HCFA concurred with our recommendation.  The HCFA stated that under the Peer Review 
Organization (PRO) contracts that will take effect between August 1999 and February 2000, 
PROs will conduct a Payment Error Prevention Program for inpatient hospital care.  Under this 
approach, HCFA will conduct an independent ongoing surveillance of inpatient payment error 
rates, both nationally and on a state-by-state basis.  The HCFA will also conduct analyses of 
discharge patterns and provide the results to the PROs.  The PROs will conduct additional 
analyses of discharge patterns and take steps to reduce or eliminate erroneous billing.  The full 
text of HCFAs comments is provided in Appendix C. 
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ii  T A B L E  O F  C O N T E N T S

PAGE

EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  i

INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

FINDINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Atypically high billings at a small number of hospitals . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Potential financial impact  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

RECOMMENDATION  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

APPENDICES

A: Clinical Data Abstraction Centers 1996 Validation Work for DRG 416 . . . . . . . . . . . . . .  A-1

B: Office of Inspector Generals Validation Work for DRG 416  . . . . . . . . . . . . . . . . . . . . . . B-1

C: Health Care Financing Administration Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-1
 INTRODUCTION

PURPOSE 
To identify hospitals with atypically high billing patterns for patients with septicemia (DRG 416). 
BACKGROUND 
In 1983, the Congress enacted a PPS, under which Medicare pays a fixed, predetermined amount 
for inpatient hospital services for each patient.  Payment for a case is determined by taking a 
hospitals individually determined base payment rate and multiplying it by the weight of the DRG 
to which the case is assigned.  A DRGs weight represents the average resources needed for cases 
in that classification relative to the average resources needed for cases in all DRGs.  Certain 
hospitals, such as psychiatric and long-term, are excluded from the PPS system. 
Claims Processing 
Cases are classified into DRGs for payment under the PPS based on the principal diagnosis, up to 
eight additional diagnoses, and up to six procedures performed during the stay, as well as age, 
sex, and discharge status of the patient.  Hospitals use codes from the International Classification 
of Diseases, Ninth Edition, Clinical Modification (ICD-9-CM) to report diagnosis and procedure 
information.  (HCFA Final Rule, Federal Register, August 30, 1996) 
When a patient is discharged, the physician will summarize information on a discharge face sheet 
which includes the principal diagnosis, defined as the condition which caused the patients 
admission, secondary or coexisting diagnoses, and procedures.  A coder, trained in medical 
classification, will use the information to assign the most appropriate ICD-9-CM code.  The 
hospital coder will review the entire medical record as part of the coding process. 
A hospital receives payment for treating a Medicare patient by preparing a claim and forwarding it 
to the Medicare fiscal intermediary.  The intermediary enters the information into its claims system 
and puts it through a series of automated screens.  These screens, called the Medicare Code 
Editor, identify cases that need further review before being classified into a DRG. 
Cases are classified by the GROUPER software program into the appropriate DRG.  This 
program classifies each case into a DRG based on diagnosis, procedure code, and demographic 
information.  It is used both to classify current cases in order to determine payment and to classify 
past cases for purposes of measuring relative hospital resource consumption.  The Medicare 
Provider Analysis and Review File contains all records for Medicare hospital inpatient discharges. 
The data in this file are used to adjust the DRG weights and to assess possible DRG classification 
changes. 
Hospital reimbursement is calculated by multiplying the relative weight of each DRG category 
by a standardized amount, as modified by certain hospital-specific factors.  Reimbursement will 
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1  increase as the relative weight increases.  Significant financial implications can result from 
hospital mis-assignment of the ICD-9-CM categories or erroneous assignment of patient 
diagnoses. 
DRG 416 
The hospital stays of patients over the age of 17 whose principal diagnosis relates to septicemia, 
are coded as DRG 416.  DRG 416 contains the ICD-9-CM codes indicating septicemias such as 
streptococcal septicemia, anaerobic septicemia, and pseudomonas septicemia.  There are 24 ICD-
9-CM codes that can lead to a coding of DRG 416. 
Septicemia (blood poisoning) can result from bacteria infecting the bloodstream in various ways. 
It is a very serious infection which can rapidly lead to septic shock and death.  Symptoms of 
septicemia include fever, chills, and nausea. 
DRG 320 
DRG 320, kidney and urinary tract infections, will result from any one of 67 principal diagnoses. 
These diagnoses include conditions such as urinary tract infection (not otherwise specified) and 
pyeloureteritis cystica. 
DRG 320 is an example of a code to which DRG 416 can be mis-classified.  It can have symptoms 
similar to DRG 416, however, diagnostic testing through a urine analysis or culture should 
differentiate the two codes. 
The mis-classification of DRG 320 to DRG 416 can have significant financial implications.  The 
1996 relative weight of DRG 416 is 1.4770 whereas the relative weight of DRG 320 is .9320. 
Therefore, mis-classifying a DRG 320 discharge as DRG 416 will result in an overpayment of 
approximately $2,000 per discharge. 
DRG Validation Efforts 
HCFA 
Through the Medicare Peer Review Organizations (PROs), HCFA contracts with two Clinical 
Data Abstraction Centers to collect clinical data from hospital medical records.  The PROs use 
this data in carrying out clinical quality improvement projects. 
The PROs are groups of practicing physicians and other health care professionals contracted by 
HCFA to oversee the care given to Medicare patients.  They are located in each State and US 
territory and decide whether care given to Medicare patients is reasonable, necessary, and 
provided in the most appropriate setting.  Each PRO is required to subcontract with the 
Abstraction Centers for DRG validation work. 
A part of the Abstraction Centers responsibility is DRG validation.  The 1996 validation effort 
consisted of a nationally representative random sample of 20,152 claims from all Medicare 
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2  inpatient hospital discharges.  There were 369 DRG 416 discharges in the sample.  The sample 
results disclosed that approximately 14 percent (53) of the sample DRG 416 discharges were 
improperly coded.  Most (49 out of 53) of the erroneously coded discharges resulted in 
overpayments to hospitals.  The total estimated overpayment attributable to DRG 416 discharges 
for 1996 was $48,930,882. 
The 49 discharges resulting in overpayments to the facility were found to belong to 20 other 
DRGs.  The most prevalent was DRG 320 which accounted for 20 of the upcoded discharges (41 
percent).  The next most prevalent were DRG 089 (Simple Pneumonia & Pleurisy Age > 17 W 
CC [with complications and comorbidities]) at 8 percent and DRG 296 (Nutritional and Misc. 
Metabolic Disorders Age > 17 W CC) at 6 percent.  A complete listing of the appropriate DRG 
codes can be found in Appendix A. 
The Abstraction Centers validation effort provides HCFA with an overall assessment of DRG 
coding and identifies potential problem DRGs.  However, a thorough analysis of the more 
problematic DRGs at the level of individual hospitals is not done. 
Office of Inspector General (OIG) 
Our office, in a study entitled, Using Software to Detect Upcoding of Hospital Bills (OEI-01-97-
00010, August 1998), performed DRG validation work on a sample of 2,622 Medicare inpatient 
hospital discharges.  Eighty-four of 2,622 sample discharges were for DRG 416.  The results of 
this validation showed that approximately 20 percent (17) of the sample DRG 416 discharges 
were improperly coded.  All 17 erroneously coded discharges resulted in overpayments to the 
hospitals. 
The erroneously coded DRG 416 discharges should have been coded to 12 other DRGs.  Twenty-
four percent (4 of 17) of the erroneously coded discharges should have been coded to DRG 320. 
DRG 089 (Simple Pneumonia & Pleurisy Age > 17 W CC) and DRG 182 (Esophagitis, Gastroent 
& Misc. Digest Disorders Age > 17 W CC) were next at 12 percent each.  A complete listing of 
the appropriate DRG codes can be found in Appendix B. 
A comparison of the tables in Appendices A and B show that seven of the DRGs are in both 
tables (these DRGs are bolded in each table).  These seven DRGs account for 69 percent of the 
erroneous records in HCFAs Abstraction Centers data and 66 percent of the erroneous records in 
the OIGs data. 
METHODOLOGY 
We used data from the Medicare Provider Analysis and Review (MedPAR) file to identify the 
number of discharges in DRG 416 for fiscal years 1993 to 1996.  We determined the increase in 
the proportion of DRG 416 discharges to total discharges from 1993 to 1996 nationally and for 
each hospital identified in the MedPAR file. 
We then identified those hospitals where more than 3 percent of their discharges were due to 
DRG 416 and the proportion of DRG 416 discharges to total discharges increased more than 100 
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3  percent from 1993 to 1996.  From these hospitals, we selected those with 50 or more discharges 
in DRG 416 in 1996.  We excluded those hospitals currently under investigation by the OIG. 
For the hospitals selected, we compiled a table of DRG 416 and DRG 320 discharges from 1993 
to 1996.  We used this information to determine the billing patterns for DRG 416 and DRG 320 
discharges over the four year period.  We also used this information to look at DRG 416 
increases, at each hospital, both from 1993 to 1996 and from year to year within that time period. 
To calculate the amount of the potential overpayment of DRG 416 in the identified hospitals, we 
first determined the national adjusted operating standardized amount by adding the labor and non-
labor columns in table 1A of the September 1, 1995 Federal Register.  Using this standardized 
amount as a basis, we determined monetary differences between the billed and appropriate DRG 
from results of our validation work.  We calculated potential overpayments by multiplying the 
applicable differences by estimates of total erroneous claims. 
This inspection was conducted in accordance with the Quality Standards for Inspections issued 
by the Presidents Council on Integrity and Efficiency. 
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4  F I N D I N G S

A SMALL NUMBER OF HOSPITALS HAVE ATYPICALLY HIGH MEDICARE 
BILLINGS FOR DRG 416. 
A relatively small number of hospitals had abnormally high DRG 416 discharges compared to 
national figures.  For 120 hospitals (out of 4,701), that met our selection criteria as stated in the 
methodology, DRG 416 discharges increased by a factor of almost 3, from 4,583 in 1993 to 
13,450 in 1996.  This represents an average increase of 43 percent a year.  Nationally, DRG 416 
discharges increased from 167,900 in 1993 to 220,441 in 1996, with an average increase of 9 
percent a year. 
This atypical pattern is also shown by the significant difference in proportions of DRG 416 
discharges to total discharges between the 120 hospitals and all hospitals.  As illustrated in the 
chart below, for the 120 hospitals, the proportion of DRG 416 discharges to total discharges 
increased from 1.57 percent in 1993 to 4.33 percent in 1996.  This represents an almost three-fold 
increase, with an average increase of  40 percent a year.  For all hospitals, this same proportion 
increased from 1.51 percent in 1993 to 1.88 percent in 1996, with an average increase of 8 
percent a year. 
Proportion of DRG 416 Discharges to Total Discharges 
1993 to 1996 
5.00% 
4.50% 
4.00% 
3.50% 
3.00% 
2.50% 
2.00% 
1.50% 
1.00% 
0.50% 
0.00% 
1993  1994  1995  1996 
DRG 416 to Total  1.57%  2.17%  3.08%  4.33% 
(120 Hospitals) 
DRG 416 to Total  1.51%  1.60%  1.73%  1.88% 
(All Hospitals) 
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5  For the 120 hospitals, the proportion of 1996 DRG 416 discharges to total discharges increased 
by a factor ranging from 2 to 19 times 1993 figures.  Specifically, for eight hospitals, the 
proportion of DRG 416 discharges to total discharges increased by a factor of more than six.  In 
26 hospitals, this proportion increased by a factor ranging between 4 and 6.  And in the remaining 
86 hospitals, this proportion increased by a factor of 2 to 3 times 1993 numbers. 
There were some hospitals that exhibited unusually high increases in DRG 416 discharges from 
1993 to 1996.  For instance, one hospitals DRG 416 discharges increased from 13 (out of 989 
total discharges) in 1993 to 113 (out of 1,324 total discharges) in 1996 -- an almost nine-fold 
increase.  Another hospitals DRG 416 discharges increased from 31 (out of 1,802 total 
discharges) in 1993 to 113 (out of 1,921 total discharges) in 1994 -- an almost four-fold increase. 
The 120 hospitals are located in 30 States.  Of the 120 hospitals, 61 are concentrated in 6 States. 
California is the top State with 15 hospitals, Texas is next with 14, and Georgia is third with 12. 
The remaining States contain hospitals numbering in the range from one to seven. 
DRG validation reviews previously conducted showed that a substantial number of the improperly 
coded DRG 416 discharges should have been coded to DRG 320.  For the 120  hospitals, DRG 
320 discharges decreased from 6,330 in 1993 to 4,792 in 1996.  Nationally, DRG 320 discharges 
increased from 172,659 in 1993 to 177,042 in 1996.  The chart below illustrates the billing pattern 
of increasing DRG 416 discharges and decreasing DRG 320 discharges for the 120 hospitals, 
from 1993 to 1996. 
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6  THE QUESTIONABLE BILLING OF DRG 416 COULD HAVE A MAJOR FINANCIAL 
IMPACT. 
From the previous DRG validation work performed by our office, we found an average per 
discharge difference of $2,254 between DRG 416 and the DRG we believe should have been 
coded.  For the 120 hospitals, the number of DRG 416 discharges exceeded national norms by 
approximately 7,345 cases.  Using the $2,254 per discharge difference from our previous work, 
we estimate that potential overpayments could be as high as $16.6 million. 
The true upcoding error rate can only be determined by undertaking a detailed claims review at 
each hospital.  Therefore, the potential overpayments at each hospital will vary according to 
applicable coding error rates. 
Proportion of DRG 416 and DRG 320 Discharges 
to Total Discharges 
1993 to 1996 
5.00% 
4.50% 
4.00% 
3.50% 
3.00% 
2.50% 
2.00% 
1.50% 
1.00% 
0.50% 
0.00% 
1993  1994  1995  1996 
DRG 416 to Total  1.57%  2.17%  3.08%  4.33% 
(120 Hospitals) 
DRG 320 to Total  2.17%  2.17%  1.88%  1.54% 
(120 Hospitals) 
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7  R E C O M M E N D A T I O N

We recommend that HCFA institute a system to identify hospitals with atypically high billings for 
DRGs identified by the Clinical Data Abstraction Centers as having a high potential for being 
upcoded. 
At the present time, HCFA uses the results of the Abstraction Centers DRG validation efforts to 
monitor the Prospective Payment System nationwide.  Although the results have not been 
published, we believe the information contained in this effort can be of great help to HCFA staff. 
An analysis of this information can point out which DRGs have a high potential for upcoding. 
The next step would be to follow an analysis such as we have presented here.  By reviewing the 
coding patterns of the individual hospitals over time, HCFA could identify facilities that may have 
a high potential for upcoding.  It is of course understood that only a record review by trained 
professionals will be able to determine if upcoding has, in fact, occurred.  The method we are 
suggesting here provides a technique to effectively focus the limited resources that HCFA can 
bring to bear on the problem. 
We have referred the 120 hospitals that we have identified as having atypically high growth in 
DRG 416 discharges to our Office of Investigations. 
AGENCY COMMENTS 
The HCFA concurred with our recommendation.  The HCFA stated that under the Peer Review 
Organization (PRO) contracts that will take effect between August 1999 and February 2000, 
PROs will conduct a Payment Error Prevention Program for inpatient hospital care.  Under this 
approach, HCFA will conduct an independent ongoing surveillance of inpatient payment error 
rates, both nationally and on a state-by-state basis.  The HCFA will also conduct analyses of 
discharge patterns and provide the results to the PROs.  The PROs will conduct additional 
analyses of discharge patterns and take steps to reduce or eliminate erroneous billing.  The full 
text of HCFAs comments is provided in Appendix C. 
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8  A P P E N D I X  A  
CLINICAL DATA ABSTRACTION CENTERS 1996 
VALIDATION WORK FOR DRG 416 
This table shows the appropriate diagnosis related groups (DRGs) for 49 upcoded DRG 416 
discharges.  The upcoding was found by the 1996 Clinical Data Abstraction Centers DRG 
validation work for DRG 416 (Septicemia Age > 17). 
Percent 
Hospital  DRG  Upcoding  of 
DRG  Weight  Description  Frequency  Total 1 
320  0.9320  Kidney & Urinary Tract Infections Age > 17 W CC 2  20  41% 
089  1.1211  Simple Pneumonia & Pleurisy Age > 17 W CC  4  8% 
296  0.9166  Nutritional & Misc. Metabolic Disorders Age > 17 W  3  6% 
CC 
144  1.0689  Other Circulatory System Diagnoses W CC  2  4% 
207  1.0287  Disorders of the Biliary Tract W CC  2  4% 
277  0.8703  Cellulitis Age > 17 W CC  2  4% 
321  0.6104  Kidney & Urinary Tract Infections Age > 17 W/O CC  2  4% 
395  0.8359  Red Blood Cell Disorders Age > 17  2  4% 
087  1.3589  Pulmonary Edema & Respiratory Failure  1  2% 
127  1.0302  Heart Failure & Shock  1  2% 
138  0.8049  Cardiac Arryhthmia & Conduction Disorders W CC  1  2% 
141  0.7149  Syncope & Collapse W CC  1  2% 
174  0.9880  G.I. Hemorrhage W CC  1  2% 
180  0.9240  G.I. Obstruction W CC  1  2% 
204  1.2020  Disorders of Pancreas Except Malignancy  1  2% 
242  1.1295  Septic Arthritis  1  2% 
316  1.2996  Renal Failure  1  2% 
331  1.0122  Other Kidney & Urinary Tract Diagnoses Age > 17 W CC  1  2% 
419  0.9223  Fever of Unknown Origin Age > 17 W CC  1  2% 
420  0.6258  Fever of Unknown Origin Age > 17 W/O CC  1  2% 
1  The total for this column will not equal 100 percent due to rounding. 
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A - 1  2  W CC represents with complications and comorbidities. 
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A - 2
 A P P E N D I X  B

OFFICE OF INSPECTOR GENERALS 
VALIDATION WORK FOR DRG 416 
This table shows the appropriate diagnosis related groups (DRGs) for 17 erroneous DRG 416 
discharges.  The errors were found by the Office of Inspector Generals validation work for DRG 
416 (Septicemia Age > 17). 
Percent 
Hospital  DRG  Upcoding  of 
DRG  Weight  Description  Frequency  Total 1 
320  0.9320  Kidney & Urinary Tract Infections Age > 17 W CC 2  4  24% 
089  1.1211  Simple Pneumonia & Pleurisy Age > 17 W CC  2  12% 
182  0.7794  Esophagitis, Gastroent & Misc. Digest Disorders Age > 17  2  12% 
W CC 
073  0.7730  Other Ear, Nose, Mouth & Throat Diagnoses Age > 17  1  6% 
180  0.9240  G.I. Obstruction W CC  1  6% 
207  1.0287  Disorders of the Biliary Tract W CC  1  6% 
272  1.0208  Major Skin Disorders W CC  1  6% 
277  0.8703  Cellulitis Age > 17 W CC  1  6% 
294  0.7579  Diabetes Age > 35  1  6% 
296  0.9166  Nutritional & Misc. Metabolic Disorders Age > 17 W CC  1  6% 
297  0.5353  Nutritional & Misc. Metabolic Disorders Age > 17 W/O CC  1  6% 
321  0.6104  Kidney & Urinary Tract Infections Age > 17 W/O CC  1  6% 
1  The total for this column will not equal 100 percent due to rounding. 
2  W CC represents with complications and comorbidities. 
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B - 1  A P P E N D I X  C

HEALTH CARE FINANCING ADMINISTRATION COMMENTS

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C - 1
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C - 2
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C - 3