News: CMS proposed IPPS changes continue DCA reductions, include HAC and excisional debridement
April 28, 2011
CDI Strategies - Volume 5, Issue 9
CMS expects a year-over-year reduction of 0.5% in payments to acute care hospitals under the proposed inpatient prospective payment system (IPPS) proposed rule released April 19. The reduction includes a documentation and coding adjustment (DCA) of negative 3.15%.
"We're very concerned that CMS continues to move forward with the inpatient PPS coding offset," says Joanna Kim, senior associate director for policy for the American Hospital Association in Washington, DC, in a special report released by HCPro Inc., last week. "We feel that it's excessive and wrongly assumes spending on inpatient hospital care has increased solely due to changes in coding.
This will be the third year that CMS has proposed some form of DCA. Last year, CMS proposed a 2.9% reduction. For FY 2010, CMS delayed its 1.9% proposal.
In a June 2010 letter to CMS, ACDIS said it “believes that the current methodology of a uniform, across-the-board reduction unfairly penalizes hospitals with true rises in patient severity and actual case mix.”
In addition in response to last year’s proposed DCA more than 240 members of Congress wrote to CMS asking them to ameliorate the proposal to no avail.
In regards to this year’s proposal, Gloryanne Bryant, RHIA, CCS, CCDS, regional managing director of HIM, NCAL Revenue Cycle, at Kaiser Foundation Health Plan, Inc. & Hospitals in Oakland, CA, says “we believe that our efforts to improve documentation and coding actually do reflect patient severity. We challenge CMS to look at other methodologies they're using."
The FY 2012 IPPS proposal also included changes to complications and comorbidities (CC)/major CC (MCC), including removing pressure ulcer diagnosis codes 707.23 (stage III) and 707.24 (stage IV) from the CC exclusion list when listed with a principal diagnosis code from 707.00–707.09., and the continued inclusion of encephalopathy as an MCC. The rule does not include any CC/MCC updates or changes based on the new ICD-9-CM codes from the March ICD-9-CM Coordination and Maintenance Committee meeting despite potential implications that the new codes may have on CC/MCC designation.
The proposed rule also includes new MS-DRGs for excisional debridement, an additional hospital-acquired condition (HAC) for contrast-induced acute kidney injury, and measures to reduce readmissions and clarify the “three-day payment window.”