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Changes are effective Oct. 1, 2019.

It’s that time of year again! Time for the Inpatient Prospective Payment System (IPPS) for fiscal year (FY) 2020. And with that comes the updates to the Medicare-Severity Diagnostic Related Groups (MS-DRGs) and the complication/comorbidity and major complication comorbidity (CC/MCC) diagnosis lists. See the Centers for Medicare & Medicaid Services (CMS) website on the final rule.

There has been much anticipation about this particular fiscal year update due to the numerous proposed changes to the CC/MCC diagnosis designation lists. Across hospitals and healthcare system there were many comments regarding the proposed CC/MCC changes were received by CMS. On page 304 of the final rule…

Specifically, commenters expressed concern that the extensive changes proposed to the severity level designations for the ICD-10-CM diagnosis codes as shown in Table 6P.1c, the majority of which would be a lower severity level (for example, CC to a non-CC), would no longer appropriately reflect resource use for patient care and could have a significant unintended or improper adverse financial impact.

The proposed changes to the CC/MCC severity level designation are also briefly discussed on page 147-148:

Similar to our process discussed in the proposed rule, we again applied the criteria to create subgroups for the two-way severity level split for the proposed MS-DRGs and found that all five criteria were met. We note that, as discussed in section II.F.14.c.1. of the preamble of this final rule, we are generally not finalizing the proposed changes to the CC/MCC severity level designations that were considered under the comprehensive CC/MCC analysis. Therefore, the above-updated analysis reflects the finalized policy.

And on page 303 the following:

after consideration of the public comments we received, we are generally not finalizing our proposed changes to the severity level designations for the ICD-10-CM diagnosis codes as shown in Table 6P.1c associated with the proposed rule, with the exception of the proposed changes to the codes related to antimicrobial resistance as discussed in greater detail below.

So, the comments made to CMS from many hospitals, coding and clinical documentation integrity (CDI) professional was heard and made an impact. There will not be significant CC/MCC changes made for FY2020. The final rule has a variety of tables that contain some very useful information.

In relation to the CC/MCC designation, these tables should be reviewed:

Table 6G.2- Principal Diagnosis Order Additions to the CC Exclusions List;
Table 6H.1- Secondary Diagnosis Order Deletions to the CC Exclusions List;
Table 6H.2- Principal Diagnosis Order Deletions to the CC Exclusions List;
Table 6I.‑‑Complete MCC List;
Table 6I.1- Additions to the MCC List;
Table 6I.2- Deletions to the MCC List;
Table 6J.‑‑Complete CC List;
Table 6J.1- Additions to the CC List;
Table 6J.2- Deletions to the CC List;
Table 6K.–Complete List of CC Exclusions.

There are five new diagnoses added to the MCC list (no deletions to the MCC list):

I26.93  Single subsegmental pulmonary embolism without acute cor pulmonale
I26.94  Multiple subsegmental pulmonary emboli without acute cor pulmonale
S02.121B  Fracture of the orbital roof, right side, initial encounter for open fracture
S02.122B  Fracture of the orbital roof, left side, initial encounter for open fracture
S02.129B  Fracture of the orbital roof, unspecified side, initial encounter for open fracture

There were 75 diagnoses added to the CC list, refer to table 6J.1 for the detailed list.  A total of five diagnoses deletions from the CC list (Table 6J.2):

D81.3  Adenosine deaminase[ADA] deficiency
          I48.1 Persistent atrial fibrillation
          Q79.6 Ehlers-Danlos syndrome
Q87.1 Congenital malformation syndromes predominantly associated with short stature
          T67.0XXA Heatstroke and sunstroke, initial encounter

In addition to the limited CC/MCC changes for FY2020, there are relative weight changes to the MS-DRGs which are noteworthy. My favorite IPPS MS-DRG table is “Table 5,” List of MS-DRGs, Relative Weighting Factors and Geometric and Arithmetic Mean Length of Stay. This excel table contains seven columns of data, from left to right; MS-DRG number, FY2020 Post-Acute DRG, Special Pay DRG (critical for discharge disposition), Major Diagnostic Category (MDC), Type of DRG – Surgical or Medical, MS-DRG Title, Relative Weights, Geometric Mean Length of Stay (LOS), and Arithmetic Mean Length of Stay. This is very helpful to coding, CDI, case management, revenue cycle and compliance professionals.

Some steps and action to take include the following:

  1. Review the MS-DRG relative weight changes Table 5: note those with the greatest change
  2. Run a data report of the past two years MS-DRGs by frequency and determine if there are MS-DRGs in your top 25 that have significant relative weight changes
  3. Review the final changes to the CC/MCC
  4. Run a data report for the past two years on the CC/MCC diagnoses with designation changes (additions and deletions) to determine the impact to your organization.
  5. Review and study the new ICD-10-CM/PCS codes
  6. Educate and Audit – this is a core function of each and every healthcare organization

The more than 2,000 pages of the IPPS final rule Federal Register publication will be released on Aug. 16, 2019, according to the CMS news bulletin, so be sure to watch for that to come out.  All changes take effect with discharges and encounters on Oct.1, 2019.

Programming Note:

Listen to Gloryanne Bryant report this story live today during Talk Ten Tuesday, 10-10:30 a.m. EST.

References/Resources: https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/AcuteInpatientPPS/index.html;



Gloryanne Bryant, RHIA, CDIP, CCS, CCDS

Gloryanne is an HIM coding professional and leader with more than 40 years of experience. She has an RHIA, CDIP, CCS, and a CCDS. For the past six years she has been a regular speaker and contributing author for ICD10monitor and Talk Ten Tuesdays. She has conducted numerous educational programs on ICD-10-CM/PCS and CPT coding and continues to do so. Ms. Bryant continues to advocate for compliant clinical documentation and data quality. She is passionate about helping healthcare have accurate and reliable coded data.

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