ACDIS update: Regulatory Committee shares templates for commenting on FY 2020 IPPS proposed rule

CDI Strategies - Volume 13, Issue 24

The ACDIS Regulatory Committee formed last fall and has been working to keep ACDIS members up to date on the regulatory changes that could potentially affect their CDI practice. One change that the committee members are currently monitoring is the proposed IPPS rule changes for fiscal year (FY) 2020 that have been published by the CMS ICD-10 Coordination and Maintenance Committee.

The ACDIS Regulatory Committee has created a pilot initiative involving the proposed change to take away the CC status for the Z codes for BMI 40-49.9 and BMI 45-49.9. The committee wants to see if mobilizing the CDI specialist community to submit comment letters to oppose this change will persuade CMS to maintain the CC status for these BMI Z codes. The comment template for this initiative as well as three other templates that the committee has created for members’ use are all available in the ACDIS Resource Library.

In the Library, members will find the following:

  1. General Morbid Obesity template: This is the committee's project template. Please take a moment to download, edit, re-save, and submit this template to CMS. We will know sometime in August if our project made an impact when CMS publishes the IPPS final rules document.
  2. Appreciation template: This can be used to submit approval of some of the proposed changes that you find helpful and you think would improve healthcare here in the USA.
  3. General concerns template: This is a template to use to express your concerns regarding the potential consequences of the proposed changes to the malignancy and sickle cell codes on the young adult and pediatric populations.
  4. Specific issue template: This template is created to help you construct a comment letter regarding a specific issue in the proposed rule changes that you feel could have a negative impact on healthcare. The committee has included a comment letter that was used to overturn the IPPS rule change for ECMO. This can be used to guide you in creating your own comment letter.

To submit your comment letter to CMS, go to Follow the instructions under the “submit a comment” tab.

If you have any questions regarding the templates or submitting comments to CMS, please contact Regulatory Committee member Candace Blankenship.

Whether or not you plan to submit a comment to CMS, ACDIS would like to hear about your plans. Please take a moment to respond to our newest polling question here.

Found in Categories: 
ACDIS Guidance, Regulations