News: ACDIS Regulatory Committee submits comments on FY 2020 IPPS proposed rule

CDI Strategies - Volume 13, Issue 28

After much consternation among the CDI community, all that remains to be done regarding the fiscal year (FY) 2020 inpatient prospective payment system (IPPS) proposed rule is to wait and see which proposals CMS finalizes and which concerns they heed from the submitted comments.

Before the comment period ended on Monday, June 24, the agency received 7,711 comments. The ACDIS CDI Regulatory Committee prepared and submitted their own, bringing forward many of the concerns raised by the larger CDI community.

Their entire comment letter is available to members and non-members in the Resource Library, but here are some of the highlights:

  • The committee and ACDIS are supportive of the following proposed changes:
    • The designation of isolated neutropenia, phosphorus disorders, cor pulmonale, fecal impaction, hypocalcemia as CCs
    • The promotion of R78.81, Bacteremia, to an MCC
    • The establishment of codes for antibiotic resistance as CCs
    • The change in designation of pressure ulcer codes to consistent CC status
    • The designation of code R63.3, Feeding difficulties, as a CC
    • The drive to recognize social determinants of health and their consequences as significant drivers of patient care needs
    • The addition of opioid-related quality measures
    • The plans to adjust disparities between high and low wage index facilities, as well as adjustments for uncompensated care
  • The committee and ACDIS are against the following proposed changes:
    • The demotion of many codes for malignancies to non-CCs
    • The changes in MCC/CC status of codes in relation to sickle-cell disease, hereditary hemolytic anemias, congenital anomalies, and chromosomal aberrations
    • The designation of moderate malnutrition as an MCC, while designating severe malnutrition as a CC
    • The designation of severe persistent asthma as a non-MCC, while codes including the term “status asthmaticus” are promoted to MCC status

In addition to their specific comments, the committee and ACDIS called on CMS to “reconsider all MCC/CC changes in the proposed rule in light of what medical issues are common in different age groups and focus changes within the proposed rule to those problems not seen in the pediatric or young adult populations.”

“We feel [that the CC/MCC changes] would have an unintentional detrimental impact on healthcare and the general public,” they wrote.

Editor’s note: To read the full letter sent to CMS from ACDIS, click here. To read more about the proposed changes, click here.

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