Note from ACDIS: 2019 IPPS proposed rule comment period closes June 25—Get your comments in!

By the ACDIS leadership team

CMS is accepting comments on the 2019 Inpatient Prospective Payment System (IPPS) proposed rule through June 25. In order for your comment to be read and considered by CMS for the final rule, you must send it no later than 5 p.m. on Monday, June 25.

You can send your comment electronically here by clicking on the “Submit a comment” button on the right upper side of the page. When commenting, please refer to file code CMS-1694-P.

There are a number of issues in the 2019 IPPS proposed rule that impact the day-to-day work of CDI professionals. The following are a few of the more noteworthy.

In the new ICD-10-CM codes for appendicitis, CMS is proposing that K35.20, acute appendicitis with generalized peritonitis without abscess, will not be classified as a complication/comorbidity that groups to MS-DRGs 338, 339, and 340, Appendectomy with Complicated Principal Diagnosis, nor will it serve as an MCC. On the other hand, K35.32, Acute appendicitis with perforation and localized peritonitis, without abscess, is classified as a complicating diagnosis with appendicitis and will serve as an MCC.

CDI professionals may wish to inform CMS that any generalized peritonitis due to acute peritonitis has a perforation by definition, according to the subheading for K35.2, and that any generalized peritonitis due to acute appendicitis—even without an abscess—should be considered a complicating diagnosis both clinically and for MS-DRG grouping.

The presence of generalized peritonitis implies that the appendix has perforated which will require additional care and a longer length of stay—and therefore should also serve as an MCC. So, you may wish to comment that K35.20, Acute appendicitis with generalized peritonitis, without abscess, should be added to the list of complicating diagnoses.

CMS received a proposal to downgrade G93.40, Encephalopathy, unspecified, as a non-CC, but is currently not prone to accept this proposal. CMS is asking for comments, however, as to what it should do. Some commenters believe that keeping an unspecified code as an MCC incentivizes CDI and coding staff not to query for added specificity like they do for heart failure (e.g., heart failure with reduced ejection fraction or heart failure with preserved ejection fraction).

Some specified encephalopathies are only CCs (e.g. hypertensive encephalopathy) or don’t serve as CCs at all (e.g., hepatic encephalopathy). You may or may not agree with CMS’ proposal to keep G93.40’s MCC status, but we recommend you review CMS’s logic and submit a comment. See page 20241 of the rule.

CMS is proposing to downgrade ICD-10-CM diagnosis code B20, Human immunodeficiency virus [HIV] disease, from an MCC to a CC. CMS expresses a belief that many patients whose previously symptomatic HIV is now under good control, and that any CC/MCCs from HIV should be accounted for the resultant condition (e.g. pneumocystis pneumonia, encephalitis due to toxoplasmosis). See page 20241 of the rule.

CMS is also proposing to eliminate 19 quality measures which it believes are duplicative in nature or no longer truly measure quality. CMS has also proposed to add one measure for claims-based 30-day unplanned readmission under the cancer hospital quality reporting program.

A simple comment on any of the above issues can take as little as a minute to do.

Click here to view the proposed rule in its entirety.

Editor’s note: Special thanks to James S. Kennedy, MD, CCS, CDIP, CCDS, for highlighting some of the IPPS proposed changes and reminding ACDIS members of the importance of commenting to CMS. To read what CDI Boot Camp Instructor Allen Frady, RN-BSN, CCDS, CCS, CRC, had to say about the proposed rule, click here.