CMS 2020 IPPS Proposed Rule: Context, Perspective, and Analysis

The public comment period closes June 24, 2019.

Earlier this year, the Centers for Medicare & Medicaid Services (CMS) announced its proposed rule changes for Inpatient Prospective Payment System (IPPS) rates and Medicare payment policies. The rule will be finalized in September, and CMS is currently accepting public comments until June 24.

The proposed rule for the 2020 fiscal year 2020 features a great number of proposed changes to the ICD-10-CM/PCS classification systems as well as the MS-DRGs. Let’s review some of the key changes and their anticipated impact.

CMS proposes to increase the wage index for hospitals below the 25^th percentile of the wage index value while decreasing the wage index for hospitals above the 75^th percentile. This proposed change would benefit rural communities, which tend to face more financial obstacles due to higher poverty rates, Medicare beneficiaries with more chronic conditions, and a larger proportion of under-insured or uninsured people.

CMS has also requested changes to the severity designation of nearly 1,500 complications and co-morbidities (CCs) and major CCs (MCCs), as well as more than 300 ICD-10-CM codes. If the rule is finalized as proposed, it will have a significant impact on clinical documentation improvement (CDI) and coding teams.

My three key takeaways:

• The sheer volume of proposed changes calls for the most accurate coding possible to capture specificity for all procedures and supplemental codes. The clinical documentation must support what’s actually happening with the patient. These changes ultimately elevate the role of coding and documentation improvement professionals, and you must remain diligent.
• Advocate for patients to have a complete and accurate clinical story. Never stop reviewing your documentation or asking for clarification as needed. Rely on your philosophies and skills to improve documentation across the entire medical record, and don’t let the relative weight for specific codes drive or change your efforts to improve documentation. Even when there are reduced relative weights, or when MCCs have been downgraded to CCs (or CCs to non-CCs), you should still be committed to your CDI program.
• I urge you as CDI professionals to review the proposed rule and then carefully and thoughtfully submit your feedback. But don’t delay! Comments must be received by 5p.m. EST on June 24. FYI, your comments must reference CMS-1716-P.

In my experience, CMS really does consider public comments; they take you seriously and are quite transparent in publishing their rationale for changes. Although some of these changes may seem controversial, others – such as moving acute myocardial infarction from an MCC to CC – reflect improvements in well how we are caring for patients with certain conditions.

From early intervention to better treatments, we’re having a positive impact on patient care. And that’s something of which to be proud.

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