Health Information Management

News: IPPS Final Rule released

CDI Strategies, August 4, 2011

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CMS released the Inpatient Prospective Payment System (IPPS) Final Rule, Monday, Aug. 1, reducing a previously proposed negative 3.9% documentation and coding adjustment (DCA) payment offset to just 2%. The 2% DCA is even lower than the 2011 rate of 2.9%.

“We’re very pleased to see that CMS has scaled back their proposed coding cuts,” says Joanna Kim, senior associate director for policy for the American Hospital Association (AHA) in Washington, DC.
“It’s good that we [hospitals] got a break,” says ACDIS Advisory Board Member James S. Kennedy, MD, CCS, managing director for FTI Healthcare in Atlanta. “But CMS will maintain its current methodology of calculating [the DCA] and will continue to assess it to hospitals until they have recouped what they believe they have overpaid.”
The DCA is an assessment originally established at the time CMS implemented MS-DRGs. It was thought that due to the increased need for specificity, facilities would focus attention on improvements to documentation and that this focus would not necessarily indicate that facilities were treating sicker patients. In the Final Rule CMS says it understands the burden the DCA places on facilities but still considers the adjustments “necessary to correct past overpayments due solely to documentation and coding improvements…”
Kennedy says the final rule contains changes to the relative weights of roughly 30 DRGs and a number of changes to CC/MCC designations.
“There was an expectation that drug-induced pancytopenia would lose its MCC status because pancytopenia due to chemo used to code to aplastic anemia, a MCC,” Kennedy says. “This happened when the CDC implemented a code for chemotherapy-induced anemia, which used to be coded to aplastic anemia; it lost its CC status altogether! So I’m elated. Hospitals—especially cancer and pediatric hospitals—should be very grateful for this.”
Kennedy also believes that comments such as those submitted by the Association of Clinical Documentation Improvement Specialists (ACDIS) played a role in ensuring the new code for brain death (code 348.82) became an MCC instead of the a CC, as CMS originally proposed.
Additional changes under the IPPS for 2012 (which takes effect on October 1, 2011) include:
  • A larger-than expected introduction of new ICD-9 codes
  • Readmission measures for acute myocardial infarction (i.e., heart attack), heart failure, and pneumonia
  • Addition of contrast-induced acute kidney injury to the list of hospital-acquired conditions
  • The addition of the Medicare Spending per Beneficiary measure to the hospital value-based purchasing program
  • Updates to payment policies and rates for those under the long-term care hospital prospective payment system
Editor’s Note: This article was adapted from an HCPro breaking news alert e-mailed to ACDIS members and available online at Read the complete Final Rule release on CMS’ web site. Lists of the CC/MCC and DRG changes are available to ACDIS members in the Forms & Tools Library, thanks to Lynne Spryszak, RN, CPC-A, CCDS, CDI education director for HCPro, Inc., in Danvers, MA, who compiled them.

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