FY 2020 IPPS proposed rule comment letter templates

The ACDIS Regulatory Committee formed last fall and has been working to keep ACDIS members up to date on the regulatory changes that could potentially affect their CDI practice. One change that the committee members are currently monitoring is the proposed IPPS rule changes for fiscal year (FY) 2020 that have been published by the CMS ICD-10 Coordination and Maintenance Committee.

The ACDIS Regulatory Committee has created a pilot initiative involving the proposed change to take away the CC status for the Z codes for BMI 40-49.9 and BMI 45-49.9. The committee wants to see if mobilizing the CDI specialist community to submit comment letters to oppose this change will persuade CMS to maintain the CC status for these BMI Z codes. Below is the comment template for this initiative as well as three other templates that the committee has created for members' use. Our power is in our numbers and our dedication to safe patient care.

These are the templates attached for your use:

  1. General Morbid Obesity template: This is the committee's project template. Please take a moment now to download, edit, re-save, and submit this template to CMS. We will know sometime in August if our project made an impact when CMS publishes the IPPS final rules document.
  2. Appreciation template: This can be used to submit approval of some of the proposed changes that you find helpful and you think would improve healthcare here in the USA.
  3. General concerns template: This is a template to use to express your concerns regarding the potential consequences of the proposed changes to the malignancy and sickle cell codes on the young adult and pediatric populations.
  4. Specific issue template: This template is created to help you construct a comment letter regarding a specific issue in the proposed rule changes that you feel could have a negative impact on healthcare. The committee has included a comment letter that was used to overturn the IPPS rule change for ECMO. This can be used to guide you in creating your own comment letter.

To submit your comment letter to CMS, go to http://www.regulations.gov. Follow the instructions under the ‘‘submit a comment’’ tab.

If you have any questions regarding the templates or submitting comments to CMS, please contact Candace Blankenship at Blankenship.Candace@mayo.edu.