Journal excerpt: Regulatory Committee proposals, notable updates
In the past year, the ACDIS Regulatory Committee has been “very active in proposing to CMS certain additions for the 2022 IPPS final rule that [they] felt would improve life for CDI professionals and better reflect the patient’s status,” says Howard Rodenberg, MD, MPH, CCDS, physician advisor for CDI at Baptist Health in Jacksonville, Florida, and the former chair of the ACDIS Regulatory Committee. Along with creating an IPPS map as a guide to the proposal process, the Regulatory Committee proposed three changes for the 2022 ruling, two of which were accepted:
- Reclassification of code B33.24, Viral myocarditis, into MDC 05, DRG 314-16
- A CC exclusion rule to include congestive heart failure (I11.0, I13.2)
“We also considered that the climate of the time demanded more attention to the social determinants of health [SDOH],” Rodenberg says. “In the proposed IPPS rule several years ago, there was a proposal to promote two social determinants we thought were important, adult failure to thrive and homelessness, to CC status. We supported these once again, but unfortunately they did not go through this year as well.”
Though the specific suggested SDOH changes weren’t included in the 2022 final rule, the rule did contain more of an emphasis on SDOH generally and added several new SDOH codes. Because of these additions, the Committee feels that CMS may be amenable to their CC proposals in future rules.
“We may be asking for the addition of adult failure to thrive and homelessness to be promoted to CC status again next year, especially as the current rule institutes more codes for social determinants of health,” says Rodenberg.
There were some significant changes in the 2022 IPPS final rule outside of the Regulatory Committee’s proposals as well. One of the changes with the biggest positive impact for CDI professionals is the new guidance on capturing laterality. Before this update, if a physician didn’t specify the laterality of a condition in their documentation, a CDI professional had to query.
“Usually, the clinician would look at the query and tell us to look at the record,” Rodenberg says. “But with this new ruling you can take laterality from other personnel notes [such as nursing notes].”
The final rule also included several significant changes to quality measures that will take place over the next several years, including measures being discontinued and others being added.
“Those CDI programs that are doing audits for quality will want to look at that section of the IPPS final rule very intensely to see the impact it will have on them,” Rodenberg says.
The list of new CCs and MCCs and any added codes are also always worth reviewing, Rodenberg says. Apart from the added codes for SDOH, CDI professionals should also be aware of the new CC for nonischemic myocardial infarction.
“This is incredibly useful for patients with elevated troponin that have chronic heart failure or kidney disease but not myocardial infarction,” Rodenberg says. “Elevated troponins always receive further evaluation and meet the criteria for a secondary diagnosis. Before we didn’t get credit for that, but now we will.”
Editor’s note: Read this full CDI Journal article here.