ACDIS update: CDI Regulatory Committee comments on proposed sepsis coding, CC/MCC changes

The ACDIS CDI Regulatory Committee submitted comments to CMS and the Centers for Disease Control and Prevention (CDC) regarding the recent proposed sepsis coding changes, supporting the proposal to update the sepsis codes to align with the sepsis-3 definition. Specifically, they suggested that the following changes be made in conjunction with the update to the ICD-10-CM table:

• Updating the ICD-10-CM Index, Table, and Official Guidelines for Coding and Reporting to accurately reflect the change in the new definition of sepsis (sepsis with organ dysfunction).
• Changing the relative weights and assignment of MS-DRGs 853-855 and 870-872 to reflect the changes in the new sepsis code set to ensure that hospitals and health systems are reimbursed appropriately for these high acuity patients.
• Assigning MCC designation to the new sepsis code set to reflect the higher acuity of these patients and, again, to ensure that hospitals and health systems are appropriately reimbursed for these high acuity patients.
• Updating of quality and patient outcome measurement algorithms that use sepsis codes as risk adjustors.

Additionally, the committee also submitted a comment letter to CMS on the fiscal year (FY) 2021 CC/MCC designations and decision process (discussed on a recent Open Door Forum call).

The committee first expressed the membership’s appreciation for CMS’s response to the public comments on the FY 2020 inpatient prospective payment system (IPPS) proposed rule. Additionally, the letter says, “ACDIS supports the new data regarding changes (both downgrades and upgrades) to the MCC/CC designation for secondary diagnoses and anticipates that they will all be included in the FY 2021 IPPS proposed rule. We look forward to working with CMS in the future on issues that impact the public’s health and safety.”

To keep up with all the committee’s work on behalf of the ACDIS membership, make sure to check out the “Regulatory Committee Insight” section under the “Thought Leadership” tab on the ACDIS website. You’ll also find copies of all their comment letters saved in this section.