IPPS Final Rule Omits Several Proposed MCC and CC Deletions

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.

A .pdf of the FY2020 IPPS Final Rule is available from CMS now here and from the Federal Register here after August 16th.



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

About the Author

Lynn Kuehn is president of Kuehn Consulting, LLC, in Waukesha, Wisconsin, a consulting firm specializing in ICD-10-PCS coding for the inpatient setting. Lynn is a nationally recognized trainer on ICD-10-PCS and other HIM-related topics. Lynn served on the AHIMA Board of Directors and authored several of AHIMA’s most popular books including ICD-10-PCS: An Applied Approach and Procedural Coding and Reimbursement for Physician Services. Together with her co-Author Theresa Jorwic, Lynn received the Triumph Literary Legacy Award from AHIMA for ICD-10-PCS: An Applied Approach. Called the “go-to” resource for learning and mastering ICD-10-PCS, ICD-10-PCS: An Applied Approach provides step-by-step instructions and exercises at all levels, and is used throughout Kuehn’s ICD-10-PCS courses authored for Libman Education.

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