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FY 2020 IPPS Final Rule: Part 1

Published on 

Tuesday, August 20, 2019

 | Recovery Auditor 
 | Quality 

CMS proposed significant changes to the current severity designation of diagnosis codes in the FY 2020 Inpatient Prospective Payment System (IPPS) Proposed Rule. Most significant were the proposed changes to current Major Comorbidities and Complications (MCCs) diagnosis codes.  

RealTime Medicare Data (RTMD) paid claims data helped to quantify the potential impact of the proposed MCC changes. Specifically, analysis of FY 2018 Medicare fee-for- service paid claims data for the state of Alabama provided answers to the following questions: 

  • What are the Top 10 diagnosis 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
N18.6End stage renal disease9,191MCCCC
E43Unspecified severe protein-calorie malnutrition3,661MCCCC
L89*All Stage 3 & 4 Pressure Ulcer Codes Combined (Note: This volume is for all 50 proposed codes)955MCCCC
I46.9Cardiac arrest, cause unspecified408MCCNon-CC
D61.810Antineoplastic chemotherapy induced pancytopenia338MCCCC
G93.5Compression of brain306MCCCC
J95.821Acute postprocedural respiratory failure207MCCCC
 All Fracture Codes Combined (Note: This volume is for 38 proposed codes)137MCCCC
K63.1Perforation of intestine (nontraumatic)130MCCCC
K57.31Dvrtclos of lg int w/o perforation or abscess w bleeding108MCCCC
I49.01Ventricular fibrillation106MCCCC
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 Claims200,727$1,939,529,965
All Claims Impacted by Proposed MCC Severity Designation Change16,455$220,445,086
Claims with MCC proposed change to CC15,796$211,561,447
Claims with MCC proposed change to Non-CC659$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.

‍Finalized Severity Changes for FY 2020

In the Final Rule many “commenters expressed concern that the extensive changes proposed to the severity level designations…would no longer appropriately reflect resource use for patient care and could have a significant unintended or improper adverse financial impact.”

CMS listened and in general did not finalize the proposed changes. Changes that were made include the following:

  • Table 6I.1 – Additions to MCC List: Five diagnosis codes were added to this list,
  • Table 6I.2 – Deletions to the MCC List: No diagnosis codes were deleted for FY 2020,
  • Table 6J.1 – Additions to the CC List: Seventy-five diagnosis codes were added to this list; and
  • Table 6J.2 – Deletions to the CC List: Five diagnosis codes were removed from the CC List.

In addition to the above tables, the Complete MCC List (Table 6I) and the Complete CC List (Table 6J can be found on the CMS FY 2020 IPPS Final Rule Home Page. Also, click here for download from this article is a document highlighting the FY 2020 additions and deletions to the MCC and CC lists for FY 2020.

Article Author: Beth Cobb, RN, BSN, ACM, CCDS
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 Protection Assessment Tool.

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.