by Lynn Kuehn, MS, RHIA, CCS-P, FAHIMA
The Inpatient Prospective Payment System (IPPS) Proposed Rule for FY2020 contained an ominous collection of MCC and CC deletions. Thankfully, the Final Rule may let us breathe a little easier. A review of the draft version of the final rule reveals that almost 150 proposed MCC deletions and approximately 1,100 proposed CC deletions were not finalized for FY2020.
Some MCC and CC designations were finalized for the new code additions as planned. There were, however, several MCC and CC designations published in the proposed rule which do not now appear in the posted draft of the final rule:
– The proposed MCC deletions for End Stage Renal Disease and Stage 3 or 4 Pressure Ulcers were not finalized, as well as almost all proposed CC designations.
– Some of the proposed CC additions such as R63.3 Feeding Difficulties and Z59.0 Homelessness were not finalized. These proposed CCs would have reflected the increased expenses related to caring for these patients.
– The entire category of Z16 for Resistance to Antimicrobial Drugs was added as CCs to indicate the increased expenses associated with the need for more powerful antibiotic therapy due to drug resistance.
Commenters expressed concern that the compressed schedule inherent in the rule process did not provide sufficient time for organizations to study and understand the potentially significant financial impact of the proposed changes. CMS appears to have listened. Be aware that while the FY2020 Final Rule brings short-term relief, these proposed changes will likely surface again in the future.
Comments on proposed changes are always important and they do get results, so we need to share our concerns during the comment period each year.
As always, review the tables for yourself to see the changes and understand their impact on your organization. The FY2020 IPPS Final Rule tables are here.
Now available! FY 2020 ICD-10 Code Updates by nationally recognized coding expert Lynn Kuehn
“Anyone can read what the changes are, but truly understanding what the changes mean, why they were made, and how to ensure compliance going into FY 2020, requires a different approach.”
— Lynn Kuehn, author of the Libman Education ICD-10 CM and PCS Updates courses