IPPS Proposed Rule: CC/MCC Designation Changes

On April 23, 2019, the Centers for Medicare and Medicaid Services (CMS) released the Inpatient Prospective Payment System (IPPS) proposed rule for fiscal year (FY) 2020. The proposed rule includes:

 

• 1,492 CC/MCC designation changes
  • 183 codes changed from Non-CC to CC
  • 1,148 codes changed from CC to Non-CC
  • 8 codes changed from CC to MCC
  • 17 codes changed from MCC to Non-CC
  • 136 codes changed from MCC to CC

Changes to CC/MCC designations included in the proposal could have a potentially dramatic effect on casemix. Before diving in, let’s review what CCs and MCCs are. The presence of a major complication or comorbidity (MCC) or complication or comorbidity (CC) generally is representative of a patient that requires more resources. Therefore, hospitals are paid more to care for these patients. Greater specificity in documenting the patient’s diagnosis allows the coder to select the diagnosis code which most accurately reflects the patient’s condition resulting in assignment to the appropriate MS-DRG.

The most significant changes that will likely reduce casemix for facilities are in bold:

• Code E42, Marasmic kwashiorkor. Downgraded from an MCC to a CC.
• Code E43, Unspecified severe protein-calorie malnutrition, would be downgraded from an MCC to a CC
• Code R62.7, Adult failure to thrive, would be upgraded to a CC
• Code L89.95, Pressure ulcer of unspecified site, unstageable, would be upgraded to a CC
• Codes in the L89 category relating to stage 3 and 4 pressure ulcers would be downgraded from MCCs to CCs
• Codes in the I21 category related to ST and non-ST elevated myocardial infarctions (STEMI, NSTEMI) would be downgraded from MCCs to CCs
• Codes for systolic, diastolic, and combined chronic heart failure would be downgraded from CCs to non-CCs
• Codes for stage 4 and 5 chronic kidney disease would be downgraded from CCs to non-CCs; the code for end stage renal disease would be downgraded from an MCC to a CC
• Code R65.11, SIRS [systemic inflammatory response syndrome] of non-infectious origin with acute organ dysfunction, would be downgraded from an MCC to a CC
• Codes for body mass index would be downgraded from CCs to non-CCs

Comments on the proposed rule are due by June 24, 2019. The comments must reference CMS-1716-P and can be uploaded to regulations.gov or mailed to: 

Centers for Medicare and Medicaid Services Department of Health and Human Services
Attention: CMS-1716-P
P.O. Box 8013
Baltimore, MD  21244-1850