News: FY 2020 IPPS proposed rule released, CC/MCC downgrades in sight

CMS released the fiscal year (FY) 2020 inpatient prospective payment systems (IPPS) proposed rule on Tuesday, April 23. Coming in at 1,824 pages long, the rule includes nearly 1,500 CC/MCC designation changes, 324 changes to the ICD-10-CM codes, updates to rural health payments, opportunities to pay for new technology, and more.

Proposed ICD-10-CM code changes include 273 new, 30 revised, and 21 deleted codes. Changes to CC/MCC designations included in the proposal included several CDI focus areas such as:

• Code E42, Marasmic kwashiorkor, would be downgraded from an MCC to a CC
• Code E43, Unspecified severe protein-calorie malnutrition, would be downgraded from an MCC to a CC
• Code R62.7, Adult failure to thrive, would be upgraded to a CC
• Code L89.95, Pressure ulcer of unspecified site, unstageable, would be upgraded to a CC
• Codes in the L89 category relating to stage 3 and 4 pressure ulcers would be downgraded from MCCs to CCs
• Codes in the I21 category related to ST-elevated myocardial infarctions (STEMI) and subsequent non-STEMI (NSTEMI) would be downgraded from MCCs to CCs (note that acute NSTEMI and type 2, 4, and 5 MIs would still be MCCs under these proposals)
• Codes for systolic, diastolic, and combined chronic heart failure would be downgraded from CCs to non-CCs
• Codes for stage 4 and 5 chronic kidney disease would be downgraded from CCs to non-CCs; the code for end stage renal disease would be downgraded from an MCC to a CC
• Code R65.11, SIRS [systemic inflammatory response syndrome] of non-infectious origin with acute organ dysfunction, would be downgraded from an MCC to a CC
• Codes for body mass index would be downgraded from CCs to non-CCs

Because rural communities tend to face more financial obstacles due to communities with higher poverty rates, beneficiaries with more chronic conditions, and more uninsured or underinsured beneficiaries, CMS is proposing to increase the wage index for hospitals below the 25^th percentile of the wage index value and decrease the wage index for hospitals above the 75^th percentile of the wage index value, Revenue Cycle Advisor reported.

Should the proposals related to paying for new technology be finalized, CMS would lower the criterion necessary for medical devices subject to one of the FDA’s expedited programs to meet the IPPS new technology add-on payment and increase add-on payments for new technology from 50% to 65%. As part of an effort to make the latest treatment innovations available to Medicare beneficiaries, CMS is proposing to waive, for two years, the requirement for evidence that FDA Breakthrough Devices demonstrate a “substantial clinical improvement.”

CMS is calling for comments on the proposals by June 24. More information can be found in the accompanying press release and fact sheet. ACDIS encourages all CDI professionals to review the proposals carefully and submit any feedback they feel necessary.

Editor’s note: To read Revenue Cycle Advisor’s coverage, click here. To read HealthLeaders Media’s coverage, click here. To read the complete proposed rule, click here.