ACDIS update: Regulatory Committee submits commentary to CMS for FY 2025 IPPS, LTCH PPS proposed rules

These comments were written and submitted by members of the ACDIS Regulatory Committee. Special thanks to: Deanne Wilk, Penny Jefferson, Mark Spoolstra, Leah Savage, Julian Everett, Angelica Cage, Debra Anoff, and Christina Merle.

The Inpatient Prospective Payment System (IPPS) final rule, issued by the CMS each year, outlines the annual updates to the Medicare payment policies and rates for inpatient hospital services. Public commentary on these proposed changes is vital, allowing healthcare providers, stakeholders, and the public to contribute insights and feedback and ensure that the final policies are effective, equitable, and considerate of real-world implications for patient care and hospital operations. 

The ACDIS Regulatory Committee reviewed the fiscal year (FY) 2025 IPPS proposed rule and submitted public comments on the following proposed recommendations and changes:

1. Revision of MS-DRG 276 Title: CMS proposes to change the title of MS-DRG 276 to "Cardiac Defibrillator Implant with MCC or Carotid Sinus Neurostimulator." While this revision aims for clarity, providers require additional time to identify the appropriate diagnosis supporting this procedure before its reclassification to MS-DRG 021.
2. MDC15 Adjustments: We agree with the proposed changes, particularly the reassignment of newborn encounters coded with specific ICD-10-CM categories from MS-DRG 794 to MS-DRG 795. This update ensures more accurate classification for newborns with specific conditions.
3. Severity Level Designations for Delirium: CMS proposes changing severity levels of certain ICD-10-CM codes for causally specified delirium from CC to MCC. This is appropriate given the significant resource use associated with delirium, which is sometimes viewed as a symptom and other times as a distinct diagnosis.
4. Inclusion of Housing Instability in Severity Designations: The proposal to reclassify seven ICD-10-CM diagnosis codes related to housing instability from non-CC to CC reflects their higher average resource costs. This aligns with the Biden-Harris Administration’s focus on social determinants of health. However, this change will only impact five cities and one state, emphasizing the need for broader implementation to support health equity.
5. New Quality Measures and Data Validation Changes: CMS proposes adopting seven new quality measures, removing five existing ones, and modifying one eCQM. While these changes aim to enhance quality assessment, the burden on hospitals to report on 25 practices in five domains is considerable, especially with the new antimicrobial use and resistance measures. Simplifying these patient safety structural measures is necessary to reduce the reporting burden.
6. Increase in eCQM Reporting Requirements: Adding new eCQMs without eliminating existing ones significantly increases resource demands on hospitals. A balanced approach is needed to manage this burden effectively.
7. Hospital Harm – Falls with Injury eCQM: We agree and support the inclusion of this measure in the eCQM set starting CY 2026.
8. Hospital Harm – Post-operative Respiratory Failure eCQM: This measure lacks clear terminology and is frequently mis-documented. More time for implementation is essential to ensure accurate reporting.
9. 30-day Risk-Standardized Death Rate for Surgical Inpatients: We support this measure, recognizing its potential to improve patient outcomes.
10. Catheter-associated Urinary Tract Infection Measure for Oncology: Reporting this measure is unfeasible for many hospitals without defined oncology units.
11. Central Line-associated Bloodstream Infection Measure for Oncology: Similar to catheter-associated urinary tract infection, many hospitals lack the defined oncology units necessary for this reporting.
12. Global Malnutrition Composite Score eCQM: We support this measure's expansion to include patients aged 18 to 64.
13. HCAHPS Survey Updates: We agree and support the proposed updates, including the addition and refinement of sub-measures, which will be publicly reported starting October 2026.
14. Hospital Readmissions Reduction Program: While no changes are proposed for this program, it is crucial to consider social determinants, psychological conditions, and treatment non-compliance that impact readmissions.
15. Infection Prevention and Control Data Reporting: Extending COVID-19 and influenza data reporting to include respiratory illnesses poses a significant burden. Reporting should be annual, similar to influenza data, to manage this burden effectively.
16. Minimizing Reporting Burden: CMS seeks comments on minimizing reporting burdens while collecting adequate data. Financial incentives are necessary to support facilities in acquiring resources and staffing for data collection.
17. Strengthening National Syndromic Surveillance Program (NSSP) Participation: To enhance participation and timely data reporting through the NSSP, financial incentives should be provided to facilities for resource acquisition and staffing.
18. Reporting to CDC’s NSSP: We agree with the requirement for hospitals and critical access hospitals to report data to the CDC’s NSSP.
19. Syndromic Surveillance Reporting Expansion: We support the expansion of syndromic surveillance reporting to inpatient settings.
20. Distribution of Graduate Medical Education (GME) Slots: CMS proposes distributing 200 additional Medicare-funded GME positions, prioritizing psychiatry. Given the national shortage of primary care physicians, adding more slots for primary care residency positions is vital.
21. Transforming Episode Accountability Model (TEAM): The TEAM model includes major surgical procedures and requires hospitals to coordinate care for 30 days post-surgery. While this model aims to enhance care coordination, incorporating home care and improving coordination with external groups is necessary. Financial incentives for safety net hospitals will support care delivery transformation efforts.

These proposed changes reflect CMS’ ongoing efforts to enhance the quality and equity of healthcare while balancing the reporting and resource demands on healthcare providers. Feedback from stakeholders is crucial to refine and implement these policies effectively.

The final rule for the IPPS is typically published by CMS in early August each year, with the policies and payment rates taking effect on October 1 of the same year. This timing allows hospitals and other stakeholders to review and prepare for the changes before the new fiscal year begins.

The ACDIS Regulatory Committee reviews regulatory policy and coding and clinical updates, comments to agencies on behalf of ACDIS, and provides summary, interpretation, and analysis to the ACDIS membership. For more information about the committee and its members, click here. Applications are open to join this committee and others until June 30, 2024; click here to apply!