MCCs Proposed for Severity Change for FY 2020

on Tuesday, 18 June 2019. All News Items | Case Management | Documentation | Coding

Alabama Claims by the Numbers

In the FY 2020 IPPS Proposed Rule CMS proposed to change 153 codes with a current severity designation of MCC to a new severity designation of CC or Non-CC. With a background in Clinical Documentation, and codes such as unspecified severe protein-calorie malnutrition (E43), acute post-procedural respiratory failure (J95.821) and end stage renal disease (N186) being proposed for a severity designation change, this felt like a significant change with an unknown impact for hospitals.

As I am apt to do, I turned to our sister company RealTime Medicare Data (RTMD) to try and quantify the potential impact. Specifically, I pulled FY 2018 Medicare fee-for- service paid claims data for the state of Alabama to answer the following questions:  

  • What are the Top 10 codes proposed for a new severity designation from MCC to CC or Non-CC?
  • What is the volume of claims and actual payment for claims that had been paid where the MS-DRG required an MCC and there was only one MCC coded, and
  • What is the volume of claims and actual payment further drilled down by MCCs with a proposed change to CC and MCCs with a proposed change to Non-CC?

This first table highlights the top 10 MCCs proposed for a severity designation change to CC or Non-CC.


Top 10 MCC Codes by Volume for Alabama
ICD-10-CM Diagnosis CodeCode DescriptionVolume of ClaimsCurrent Severity DesignationProposed Severity Designation
N18.6 End stage renal disease 9,191 MCC CC
E43 Unspecified severe protein-calorie malnutrition 3,661 MCC CC
L89* All Stage 3 & 4 Pressure Ulcer Codes Combined (Note: This volume is for all 50 proposed codes) 955 MCC CC
I46.9 Cardiac arrest, cause unspecified 408 MCC Non-CC
D61.810 Antineoplastic chemotherapy induced pancytopenia 338 MCC CC
G93.5 Compression of brain 306 MCC CC
J95.821 Acute postprocedural respiratory failure 207 MCC CC
  All Fracture Codes Combined
(Note: This volume is for 38 proposed codes)
137 MCC CC
K63.1 Perforation of intestine (nontraumatic) 130 MCC CC
K57.31 Dvrtclos of lg int w/o perforation or abscess w bleeding 108 MCC CC
I49.01 Ventricular fibrillation 106 MCC CC
Data Source: RTMD data representing Alabama paid claims in FY 2018.

This next table compares all Alabama paid claims for FY 2018 to claims with MCCs proposed for severity designation change.

FY 2018 Compare
 Claims VolumeActual Payment
All Alabama Paid Claims 200,727 $1,939,529,965
All Claims Impacted by Proposed MCC Severity Designation Change 16,455 $220,445,086
Claims with MCC proposed change to CC 15,796 $211,561,447
Claims with MCC proposed change to Non-CC 659 $8,883,639
Note: MCC Severity Rate Change Claims represent MS-DRGs impacted by presence of MCC and the claim only had one MCC coded.

While a decrease in revenue is never good news, it did ease my anxiety a little to find the potential impact is only 11% of actual payment could be affected if the proposed code changes are finalized based on current Alabama volumes and payments noted above. Further, keep in mind, the actual payment loss would be even less as a hospital will still get paid an MS-DRG, it will just be one with a lower relative weight and payment.

You can read more about all of the CC/MCC proposed severity designation changes in a related MMP article. Also, it’s not too late to comment on the Proposed Rule. CMS is accepting comments through 5 p.m. EDT on June 24, 2019.

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-five 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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