Proposed IPPS Includes 15 MS-DRGs Changes

The IPPS proposed rule is dense reading.

The Centers for Medicare & Medicaid Services (CMS) released its Inpatient Prospective Payment System (IPPS) Proposed Rule for the 2022 fiscal year (FY) on April 27. This proposed rule is packed with information for inpatient services for FY 22, covering a whopping 1,091 pages. Comments are due by June 28 at 5 p.m. EST. Comments can be submitted at http://www.regulations.gov.

There are 15 proposed changes to Medicare Severity Diagnosis-Related Groups (MS-DRGs) in the proposed rule, including shifts from 981-983 (Extensive OR Procedures Unrelated to Principal Diagnosis) to 987-989 (Non-Extensive OR Procedures Unrelated to Principal Diagnosis). There were 11 additional proposals for MS-DRG amendments that were not accepted.

There are 10 shifts of ICD-10-PCS procedure codes from OR to Non-OR or Non-OR to OR. For example, 22 PCS codes describing open drainage of subcutaneous tissue and fascia (Table 0J9) will be moved to the non-OR classification.

The ICD-10-CM and ICD-10-PCS classifications are expanding between FY 21 and FY 22. See the table below:

The new diagnosis codes can be found in Table 6A. The new procedure codes can be found in Table 6B. These tables are associated with the proposed rule and can be found using the link in the Resources section. The ICD-10-CM and ICD-10-PCS codes effective on Jan. 1, 2021 are included in the changes for FY 22. Comments can be submitted regarding Major Diagnostic Category (MDC), MS-DRG, severity level for diagnosis (CC or MCC status), and OR status (DRG OR or non-OR). Comments regarding the actual codes will not be reviewed, as the Coordination and Maintenance Committee finalizes the codes.

This proposed rule also contains the possibility of two official updates per year, which would occur on April 1 and Oct. 1. This proposal was discussed during the March Coordination and Maintenance Committee Meeting, and CMS has requested feedback on the change.

There are also proposed changes regarding Complication/Comorbid Condition (CC) status. Additionally, CMS is requesting comments regarding unspecified codes. There is a proposed change to shift the unspecified codes to non-CC status. The current and proposed breakdown are as follows:

Please note that proposed changes were based only on V38.1 diagnosis codes.

This proposed rule also contains updates to the Medicare code edits (MCEs), surgical hierarchy, and cost-to-charge ratios for the 19 major cost centers. The MCE changes are minimal, and restricted to the new FY 22 codes. In this fiscal year, the surgical hierarchy in MDC 5 (Circulatory System) has been amended.

As you can see, there is much to consider and prepare for come Oct. 1, 2022. 

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