How Will FY2020 IPPS Proposed Rule Affect Hospital CDI Programs?

In April, CMS issued the fiscal year (FY) 2020 Inpatient Prospective Payment Systems (IPPS) proposed rule. The proposed rule notably includes approximately 1500 complications or comorbidities (CC)/major complications or comorbidities (MCC) designation changes and 324 changes to International Classification of Diseases, Tenth Revision, Clinical Modification codes, along with several other updates. The designation changes are an effort to respond to the notion that the CC/MCC assignment are no longer appropriate as conditions and factors have shifted.

From a clinical documentation improvement (CDI) perspective, hospitals that focus on CC/MCC designation alone could see effects on their quality ratings if these conditions are not fully evaluated. Some examples of the changes to CC/MCC designations are listed below. Several of the changes fall into chronic conditions that are considered significant by CMS and are areas that quality, as well as clinical documentation integrity programs, often focus their work. These areas include:

• Obesity Codes for body mass index <19.9 and between 40-49.9; Downgrade from CCs to non-CCs
• Malnutrition Code E42: Marasmic kwashiorkor; Downgrade from an MCC to a CC Code E43: Unspecified severe protein-calorie malnutrition; Downgrade from an MCC to a CC
• Heart Failure Certain codes in the I21 category related to ST-Elevation Myocardial Infarction (STEMI) and subsequent non-STEMI (NSTEMI); Downgrade from MCCs to CCs (Note: certain acute NSTEMI and MIs would remain MCCs) Codes for systolic, diastolic, and combined chronic heart failure; Downgrade from CCs to non-CCs
• Chronic Kidney Disease Codes for stage 4 and 5 chronic kidney disease; Downgrade from CCs to non-CCs Code for end stage renal disease; Downgrade from an MCC to a CC
• Cancer Codes when assigned as a secondary diagnosis; Downgrade from CCs to non-CCs Most cancers invisible to the eye and malignancies invisible to external inspection; Downgrade from CCs to non-CCs

Impacts on Hospital Reimbursements

The proposed changes will greatly impact the reimbursement of hospitals and other facilities across the board. The resources required for treatment of these conditions, many of which are no longer considered MCC/CCs, will be a financial burden due to the proposed IPPS rule. More specifically, the changes infer that patients with these disease burdens and conditions do not require as many resources as patients without the condition. In areas such as obesity/malnutrition, heart failure, and chronic kidney disease, it is difficult to agree that these would not require additional resources such as labs, pain management, intakes and outputs, additional imaging, daily weights, and, oftentimes, a higher level of nursing care in general.

Regarding the downgrade of the secondary diagnoses of cancer, the rationale given to downgrade was stated that because it is not the condition that caused the patients admission to the hospital, it does not significantly impact resource use. As in the conditions discussed above, it is difficult to agree that a secondary diagnosis of cancer may not require pain control, lab monitoring, follow-up imaging, or consideration for further complications. Also, if a patient is undergoing active chemotherapy for a secondary diagnosis of cancer, there is always potential for further evaluation, monitoring or treatment.

Conversely, there are proposed changes to CC/MCC designations that are positive and will more accurately reflect the overall patient condition. Some of these include:

• Pressure Ulcers Stage 1, 2 pressure ulcers, including unspecified and unstageable; Upgrade from Non-CCs to CCs; Stage 3 and 4, downgrading from MCC to CC, thus all pressure ulcers now a CC
• Asthma Severe persistent asthma with acute exacerbation; Upgrade from CC to an MCC
• Diabetes Codes for drug-induced or chemical diabetes; Upgrade to CCs

CMS has sought public comment on the proposed rule. To view all submitted thoughts and comments, visit https://www.regulations.gov/document?D=CMS-2019-0073-0003. If finalized, proposed changes would affect discharges occurring on or after October 1, 2019.