With the last 14 months being impacted by the COVID-19 public health emergency (PHE), we experienced significant changes and revisions to policies across the continuum of healthcare. It’s time once again for the Inpatient Prospective Payment System (IPPS) proposed rule for the coming fiscal year 2022 (FY2022). Here are “some” highlights from the CMS proposed IPPS rule:
- The add-on MS-DRG payment for COVID-19, is proposed to continue until the FY in which the pandemic is declared over (ends).
- CMS is proposing to extend the New COVID-19 Treatment Add-on Payment or NCTAP for eligible COVID-19 products for through the end of the fiscal year in which the PHE ends.
- CMS is also proposing to discontinue NCTAP for discharges on or after 10/1/2021 for a product that is approved for new-technology add-on payments beginning FY2022.
- New technology add-on payments are recommended to continue for 14 technologies for one additional year. Under the CMS policy Medicare pays hospital the applicable MS-DRG rate and up to an additional 65% and 75% for certain antimicrobials, of the cost approved new technology. Keep in mind that the new technology add-on payment is no budget neutral and is generally limited to the 2–3-year period following the FDA approval or clearance for marketing.
- For the Hospital-Acquired Condition (HAC) program, CMS is proposing to:
- Establish a measure suppression policy; and proposing to suppress the third and fourth quarters of CY2020 CDC National Healthcare Safety Network Healthcare-Associated Infection (HAI) and CMS PSI 90 data from performance calculations for FY2022 and FY2023.
- Update the regulatory test to reflect the renaming of the Hospital Compare website now referred to as “Care Compare”.
- New, revised, or deleted ICD-10-CM codes: the proposed rule has 153 new diagnosis codes, 22 revised and 30 deleted (invalidated) codes. For ICD-10-PCS changes, review the Federal Register posted rule.
For HIM Coding and Clinical Documentation Integrity (CDI) specialists the changes in Diagnostic Related Groups relative weights, the addition or deletion of Complication/Comorbidity (CC) or Major Complication/Comorbidity (MCC) within IPPS is very important. Please go to the following link to read over the CMS rule summary which includes Long Term Care Prospective Payment rule in addition to IPPS: Fiscal Year (FY) 2022 Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long Term Care Hospital (LTCH) Rates Proposed Rule (CMS-1752-P) | CMS
In addition, the Federal Register version of all 1914 pages of the IPPS proposed rule is available at: 2021-08888.pdf (federalregister.gov) Comments on this proposed rule are welcome through June 28, and you can send them via the following three options:
- Electronically. You may (and we encourage you to) submit electronic comments on this regulation to http://www.regulations.gov. Follow the instructions under the “submit a comment” tab.
- By regular mail. You may mail written comments to the following address ONLY: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1752-P, P.O. Box 8013, Baltimore, MD 21244-1850
- By express or overnight mail. You may send written comments via express or overnight mail to the following address ONLY: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1752-P, Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850.
Being this is the “proposed” rule we will need to of course watch for the FINAL rule to come out around the end of July or the beginning of August and obtain education on the impact for clinical coding and CDI for specific MS-DRG changes.
Written by Gloryanne Bryant, RHIA, CDIP, CCS, CCDS, AHIMA Approved ICD-10-CM/PCS Trainer
Reimbursement Management Consultants (RMC) can provide assistance with medical coding support, auditing, education, compliance consulting, and HCC/risk adjustment services. RMC is a woman-owned, US-based and operated company which specializes in a variety of medical coding and auditing services. Contact us here.