FY 2021 IPPS Proposed Rule: O.R. and Non-O.R. Procedure Codes

on Tuesday, 09 June 2020. All News Items | Case Management | Quality

Proposed ICD-10-PCS Procedure Code O.R. & Non-O.R. Designation

In last week’s FY 2021 IPPS Proposed Rule article we delved into the details of what CMS is proposing related to MS-DRGs. In keeping with coding proposals within the proposed rule, this week’s article highlights proposed ICD-10-PCS O.R. and Non-O.R. designation changes.

Operating Room (O.R.) and Non-O.R. Procedure Codes Background

Before we get into the details of what is being proposed, I believe it’s important to have a basic understanding of O.R. vs. Non-O.R. procedures.

  • First, each ICD-10-PCS procedure code is either designated as an O.R. procedure for purposes of MS-DRG assignment (“O.R. procedures”) or is not designated as an O.R. procedure for purposes of MS-DRG assignment (“Non-O.R. procedures”)
  • Second, ICD-10-PCS codes classified as an O.R. procedure are further classified as either extensive or non-extensive.
  • Third, ICD-10-PCS codes classified as Non-O.R. are further classified as either affecting the MS-DRG assignment or not affecting the MS-DRG assignment. When the Non-O.R. procedure does impact MS-DRG assignment, CMS refers to these ICD-10-PCS codes as “Non-O.R. affecting the MS-DRG assignment.”

Proposed New ICD-10-PCS Codes

Table 6B. – New Procedure Codes is made available in association with the Proposed Rule. For FY 2021 CMS is proposing:

  • 116 new ICD-10-PCS codes with O.R. designation, and
  • 105 new ICD-10-PCS codes with Non-O.R. designation.

CMS Comprehensive, Systematic Review of ICD-10-PCS Procedure Codes: Request for Comments

CMS indicated in the FY 2020 IPPS Prosed Rule that they planned to undertake a multi-year project to conduct a comprehensive, systematic review of the ICD-10-PCS procedure codes.  In the FY 2021 IPPS Proposed Rule, CMS acknowledges that “while we have typically evaluated procedures on the basis of whether or not they would be performed in an operating room, we believe that there may be other factors to consider with regard to resource utilization, particularly with the implementation of ICD-10. Therefore, we are again soliciting feedback on what factors or criteria to consider in determining whether a procedure is designated as an O.R. procedure in the ICD-10-PCS classification system for future consideration. Commenters should submit their recommendations to the following email address: This email address is being protected from spambots. You need JavaScript enabled to view it. by October 20, 2020.”

FY 2021 Proposed for O.R. Procedure Re-designation to Non-O.R. Procedure

CMS is proposing to re-designate the following ICD-10-PCS procedure codes describing endoscopic revision of feeding devices from O.R. to Non-O.R. Procedures:

  • 0DW08UZ: Revision of feeding device in upper intestinal tract, via natural or artificial opening endoscopic,
  • 0DW68UZ: Revision of feeding device in stomach, via natural or artificial opening endoscopic, and
  • 0DWD8UZ: Revision of feeding device in lower intestinal tract, via natural or artificial opening endoscopic.

FY 2021 Proposed Non-O.R. Procedure Re-designation to O.R. Procedure

Percutaneous/Endoscopic Biopsy of Mediastinum

A request was made that all procedures performed within the mediastinum by an open or percutaneous endoscopic approach, regardless if it is diagnostic or therapeutic, should be designated as O.R. procedures due to the procedures requiring great skill and the potential risk to the patient due to the structures within the mediastinum. Four of six ICD-10-PCS codes that CMS analyzed are already designated as O.R. procedures. Therefore, CMS is proposing to re-designate the following two codes as O.R. procedures:

  • 0WBC3ZX: Excision of mediastinum, percutaneous approach, diagnostic, and
  • 0WBC4ZX: Excision of medistinum, percutaneous endoscopic approach, diagnostic.

Percutaneous Endoscopic Chemical Pleurodesis

CMS agreed with a requestor that ICD-10-PCS procedure code 3E0L4GC (introduction of other therapeutic substance into pleural cavity, percutaneous approach) typically requires the resources of an O.R. and is proposing to re-designate this procedure code as an O.R. procedure.

Percutaneous Endoscopic Excision of Stomach

CMS is proposing to re-designate two codes as O.R. Procedures:

  • 0DB64ZZ: Excision of stomach, percutaneous endoscopic approach, and
  • 0DB64ZX: Excision of stomach, percutaneous endoscopic approach, diagnostic.

During their review, CMS noted inconsistencies in how procedures involving the excision of stomach are designated and are proposing that the following five ICD-10-PCS codes be redesignated as Non-O.R. procedures:

  • 0DB63Z3: Excision of stomach, percutaneous approach, vertical,
  • 0DB63ZZ: Excision of stomach, percutaneous approach,
  • 0DB67Z3: Excision of stomach, via natural or artificial opening, vertical,
  • 0DB67ZZ: Excision of stomach, via natural or artificial opening, and
  • 0DB68Z3: Excision of stomach, via natural or artificial opening endoscopic, vertical.

Percutaneous Endoscopic Drainage

CMS agreed with a requestor that the following codes describing procedures involving laparosopic drainage of peritoneum, peritoneal cavity, and gallbladder would commonly be performed under general anesthesia and are proposing to desgnate the codes as O.R. procedures:

  • 0D9W4ZZ: Drainage of peritoneum, percutaneous endoscopic approach
  • 0D9W40Z: Drainage of peritoneum with drainage device, percutaneous endoscopic approach
  • 0W9G4ZZ: Drainage of peritoneal cavity, percutaneous endoscopic approach
  • 0W9G40Z: Drainage of peritoneal cavity with drainage device, percutaneous endoscopic approach
  • 0F944ZZ: Drainage of gallbladder, percutaneous endoscopic approach
  • 0F9440Z: Drainage of gallbladder with drainage device, percutaneous endoscopic approach
  • 0F944ZX: Drainage of gallbladder, percutaneous endoscopic approach, diagnostic

As a result of further analysis, the following codes are being proposed for re-designation from Extensive O.R. procedures to Non-Extensive O.R. Procedures:

  • 0D9W00Z: Drainage of peritoneum with drainage device, open approach
  • 0D9W0ZX: Drainage of peritoneum, open approach, diagnostic
  • 0D9W0ZZ: Drainage of peritoneum, open approach
  • 0D9W4ZX: Drainage of peritoneum, percutaneous endoscopic approach, diagnostic
  • 0W9G00Z: Drainage of peritoneal cavity with drainage device, open approach
  • 0W9G0ZZ: Drainage of peritoneal cavity, open approach
  • 0F9400Z: Drainage of gallbladder with drainage device, open approach
  • 0F940ZZ: Drainage of gallbladder, open approach
  • 0F940ZX: Drainage of gallbladder, open approach, diagnostic

Control of Bleeding

CMS agreed with a requestor and is proposing to re-designate ICD-10-PCS procedure code 0W3G0ZZ (Control bleeding in peritoneal cavity, open approach) from a Non-O.R. to O.R. procedure consistent with other procedures performed to control bleeding that are designated as O.R. procedure.

Inspection of Penis

CMS agreed with a requestor that ICD-10-PCS procedure code 0VJS0ZZ (Inspection of penis, open approach) typically requires the resources of an operating room and are proposing to re-designate this procedure code as an O.R. procedure.

O.R. and Non-O.R. issues can be found on pages 32542 – 32549 of the proposed rule. MMP strongly encourages key stakeholders at your facility take the time to review the entire proposed rule and submit comments. CMS is accepting comments through 5 p.m. EDT on July 10, 2020.

Article by Beth Cobb

Beth Cobb, RN, BSN, ACM, CCDS, is the Manager of Clinical Analytics at Medical Management Plus, Inc.  Beth has over twenty-eight years of experience in healthcare including eleven years in Case Management at a large multi-facility health system. 

In her current position, Beth is a principle writer for MMP’s Wednesday@One weekly e-newsletter, an active member of our HIPAA Compliance Committee, MMP’s Education Department Program Director and co-developer of MMP’s proprietary Compliance Risk Assessment (CRA) Tool. You may contact Beth at This email address is being protected from spambots. You need JavaScript enabled to view it..

This material was compiled to share information.  MMP, Inc. is not offering legal advice.  Every reasonable effort has been taken to ensure the information is accurate and useful.

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