MCCs Proposed for Severity Change for FY 2020
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 Code||Code Description||Volume of Claims||Current Severity Designation||Proposed 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)
|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|
|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 Volume||Actual 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.
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.