The Centers for Medicare & Medicaid Services (CMS) plans limited changes to complications and comorbidities (CC) in fiscal year (FY) 2012, but proposes new MS-DRGs for excisional debridement as well as an additional hospital-acquired condition (HAC). These and other changes are part of the inpatient prospective payment system (IPPS) proposed rule posted April 19. The proposals would make adjustments to existing IPPS policies and also pave the way for future changes as a result of the Patient Protection and Affordable Care Act (PPACA).
Overall, CMS expects a year-over-year reduction of 0.5% in payments to acute care hospitals under the FY 2012 IPPS. The reduction includes a documentation and coding adjustment of -3.15%, eliciting disappointment from the hospital community.
"We're very concerned that CMS continues to move forward with the inpatient PPS coding offset," says Joanna Kim, senior associate director for policy for the American Hospital Association in Washington, DC. "We feel that it's excessive and wrongly assumes spending on inpatient hospital care has increased solely due to changes in coding. We are, however, pleased that CMS has not proposed further documentation and coding cuts to the LTCH PPS [long-term care hospital prospective payment system]."
Gloryanne Bryant, RHIA, CCS, CCDS, regional managing director of HIM, NCAL Revenue Cycle, at Kaiser Foundation Health Plan, Inc. & Hospitals in Oakland, CA, agrees. "We believe that our efforts to improve documentation and coding actually do reflect patient severity, and we challenge CMS to look at other methodologies they're using." Bryant encourages hospitals to comment on the offset, especially if they can provide data to support their position.
The 2012 proposed rule includes limited changes to the list of CCs/major CCs (MCC) and the associated CC exclusion list. James S. Kennedy, MD, CCS, managing director for FTI Healthcare in Atlanta, cautions that the rule does not include any CC/MCC updates or changes based on the new ICD-9-CM codes from the March ICD-9-CM Coordination and Maintenance Committee meeting. Instead, CMS will accept comments on the effect of these new codes after they are published in May. Kennedy believes that some of the new codes could have CC/MCC implications, such as new codes from the stages of acute kidney injury or drug-induced pancytopenia, which stakeholders should watch for.