Part 3: New 2022 IPPS Changes
Pat Maccariella‑Hafey
RHIA, CDIP, CCS, CCS‑P, CIRCC
Executive Director Of Education
AHIMA‑Approved ICD‑10‑CM/PCS Trainer and Ambassador
In the previous two parts of this four part series, we discussed the new ICD-10-CM diagnosis code changes and ICD-10-PC procedure code changes. In this session we will review the major IPPS changes for FY2022.
IPPS Changes Financial
On August 2, 2021, CMS published the Final Rule for IPPS (CMS-1752F) FY2022 IPPS Final Rule
Acute care hospitals that report quality data and that are meaningful users of EHRs will receive approximately a 2.5% increase in Medicare operating rates. Hospitals that do not submit quality data would lose 1/4 (-25%) of the market basket update (-25% of the 2.5% as above) and hospitals that are not meaningful users of EHRs will be subject to a ¾ or 0.75%) reduction of the market basket for FY 2022.
CMS is projecting that with the 2.5% increase and other changes to IPPS policies it will boost total IPPS payments in FY2022 by roughly $3.7 billion.
As a result of the ongoing COVID-19 public health emergency, CMS will extend its “New COVID-19 Treatments Add-on Payments” (NCTAP) through the end of the fiscal year (9/30/22) in which the PHE ends for all eligible products and new tech add-on payments for FY2022 with any new technology add-on payment reducing the amount of the NCTAP. (This is done by increasing the normal DRG relative weight by 20% for cases that have U07.1 coded)
There were no new changes to the Post-Acute Care Transfer Policy for FY2022.
Quality Measures
Also, in light of the COVID-19 PHE, CMS finalized adjustments to its hospital quality measurement and value programs. Specifically, for FY 2022, CMS will suppress (i.e., not use) most hospital value-based purchasing program measures. As a result, hospitals would receive neutral payment adjustments under the VBP for FY 2022. In addition, CMS will exclude performance data from 2020 in calculating Hospital Acquired Condition Reduction Program performance for FYs 2022 and 2023. Lastly, for the FY 2023 Hospital Readmissions Reduction Program, CMS will suppress the pneumonia readmissions measure, and to exclude COVID-19 diagnosed patients from the remaining five measures.
Hospitals are required to report measures and meet the administrative requirements of the IQR program to avoid having their annual market basket update reduced by one quarter. The IQR also includes requirements to report electronic clinical quality measures (eCQMs) that align with the eCQM reporting requirements in the Promoting Interoperability Program. (Generated by provider’s E.H.R.) See https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/ClinicalQualityMeasures.html
CMS is finalizing to adopt five new measures, remove three existing measures, and make changes to the existing EHR certification requirements along with other administrative updates. CMS is also requested comment on the potential future adoption of a COVID-19 mortality measure and patient reported outcome measure following elective primary total hip and/or knee arthroplasty. See this link for details of these changes: https://www.cms.gov/newsroom/fact-sheets/fiscal-year-fy-2022-medicare-hospital-inpatient-prospective-payment-system-ipps-and-long-term-care-0
Regarding Hospital Value Based Purchasing Program In Final Rule FY2022 CMS is:
- Establishing the measure suppression policy for the duration of the COVID-19 PHE;
- Suppress the Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS), Medicare Spending Per Beneficiary (MSPB), and five HAI measures, for the FY 2022 program year, and
- Suppress the Pneumonia (PN) 30-Day Mortality Rate (MORT-30-PN) measures measure for the FY 2023 program year;
- Remove the Patient Safety and Adverse Events Composite (CMS PSI 90) measure beginning with the FY 2023 program year. CMS continues to consider patient safety a high priority, but because the CMS PSI 90 measure is also used in the HAC Reduction Program, CMS believes removing this measure from the Hospital VBP Program will reduce the provider and clinician costs associated with tracking duplicative measures across programs.
CMS is also finalizing their proposal to revise the scoring and payment methodology for the FY 2022 program year such that hospitals will not receive Total Performance Scores. Instead, we are finalizing proposal to award each hospital a payment incentive multiplier that results in a value-based incentive payment that is equal to the amount withheld for the fiscal year (2 percent).
For the Hospital-Acquired Condition (HAC) Reduction Program, no changes to the scoring methodology will be made in FY2022.
For the FY2022 Hospital Readmissions Reduction Program (HRRP) 30 day readmissions, CMS is
- Finalizing to adopt a cross-program measure suppression policy until after the COVID-19 public health emergency (PHE); and finalizing to suppress the Hospital 30-Day, All-Cause, Risk-Standardized Readmission Rate (RSRR) following Pneumonia Hospitalization measure (NQF #0506) beginning with the FY 2023 program year;
- Modifying the remaining five condition-specific readmission measures to exclude COVID-19 diagnosed patients from the measure denominators, beginning with the FY 2023 program year; along with using MedPAR data that aligns with the applicable period for FY2022.
- In response to the COVID-19 public health emergency, CMS is excluding Quarter 1 and Quarter 2 2020 data from all program calculations for HRRP.
MS-DRG Changes
There were several changes involving MS-DRGs.
Pre-MDC: Chimeric Antigen Receptor(CAR) T-cell and Other Immunotherapies
The above in green was added to the MS-DRG name. Also, 16 new XW0—- codes were added to reflect the addition of new technology substances/drugs added for FY2022.
MDC 3: Ear, Nose and Throat Procedures: CMS is changing the designation of 0JB60ZZ, 0JB70ZZ and 0JB80ZZ describing excision of subcutaneous tissue of chest, back and abdomen to “Non extensive procedure” codes. So, if there is not a PDX in MDC 3, they will now group to MS-DRGS 987, 988, 989 for Non-Extensive O.R. Procedures Unrelated to PDX with MCC, with CC, and without CC/MCC.
CMS is reassigning the three procedure codes describing excision of subcutaneous tissue of chest, back, or abdomen (0JB60ZZ, 0JB70ZZ, and 0JB80ZZ) from MS-DRGs 140, 141, and 142 (Major Head and Neck Procedures with MCC, with CC, and without CC/MCC, respectively) to MS–DRGs 143, 144, and 145 (Other Ear, Nose, Mouth And Throat O.R. Procedures with MCC, with CC, and without CC/MCC, respectively) in MDC 03 for FY 2022.
Of the 82 codes reviewed, three codes, 0W310ZZ, 0W313ZZ and 0W214ZZ, Control of bleeding of cranial cavity, open, percutaneous or percutaneous endoscopic should map to and warrant grouping to MS-DRGs 23, 24, 25, 26, and 27 (“craniotomy” MS-DRGs) in MDC 01. They were removed from MS-DRGs 143, 144 and 145 (Other Ear, Nose, Mouth And Throat O.R. Procedures with MCC, with CC, and without CC/MCC, respectively)
MDC 4: Respiratory System: Of the procedures currently assigned to MS–DRGs 163, 164, 165, 166, 167, and 168, we found 17 procedure codes in MS-DRGs 163, 164, and 165 describing laser interstitial thermal therapy (LITT) of body parts that do not describe areas within the respiratory system, which would not be clinically appropriate to maintain in the logic. CMS is finalizing to reassign these 17 procedure codes from their current MS-DRG assignments in MDC 04, and from the additional MDCs and MS-DRGs identified during their review that were found to be clinically inappropriate, to their clinically appropriate MDC and MS-DRGs as shown in Table 6P.2b which is on the CMS website. See the link below in References.
CMS also identified five procedure codes describing repair of the esophagus procedures currently assigned to MS-DRGs 163, 164, and 165 for Major Chest Procedures that would not be clinically appropriate to maintain in the logic. The procedure codes are:
- 0DQ50ZZ (Repair esophagus, open approach),
- 0DQ53ZZ (Repair esophagus, percutaneous approach),
- 0DQ54ZZ (Repair esophagus, percutaneous endoscopic approach),
- 0DQ57ZZ (Repair esophagus, via natural or artificial opening), and
- 0DQ58ZZ (Repair esophagus, via natural or artificial opening endoscopic),
Therefore, we are removing procedure codes 0DQ50ZZ, 0DQ53ZZ, 0DQ54ZZ, 0DQ57ZZ, and 0DQ58ZZ from the logic in MDC 04 and DRGS 163-165. They will be assigned to other appropriate MS-DRGs depending on the PDX.
Also, As a result of our preliminary review of ALL codes in MS-DRGs 163, 164, 165, 166, 167, and 168, for FY 2022 CMS is finalizing the reassignment of the listed 26 procedure codes (9 procedure codes describing repair of pulmonary or thoracic structures, and 17 procedure codes describing procedures performed on the sternum or ribs) from MS-DRGs 166, 167, and 168, Other Respiratory System OR Procedures to MS-DRGs 163, 164, and 165, Major Chest Procedures in MDC 04. See Table 6P.2c from the link below. Example is 02QP4ZZ, Repair Pulmonary Trunk, Percutaneous Endoscopic Approach.
CMS plans to do data analyses of all codes in Tables 6P1e and 6P1f to see if these MS-DRGS are warranted and analysis of the creation of the new procedure codes assigned to these MS-DRGs.
MDC 5: Cardiovascular System: CMS is reassigning Impella™ heart assist devices fromMS-DRG 215 (Other Heart Assist System Implant) to MS-DRGs 216, 217, and 218 (Cardiac Valve and Other Major Cardiothoracic Procedures WITH Cardiac Catheterization with MCC, with CC, and without CC/MCC, respectively) and MS-DRGs 219, 220, 221 (Cardia Valve and Other Major Cardiothoracic Procedures WITHOUT Cardiac Catheterization with MCC, with CC, and without CC/MCC, respectively as the short term Impella™ devices placed intraoperatively require less resources. Hence the two pathways above depending on use.
For Type 2 MI, requester said if I21.A1 is coded with PDX in MDC 05, DRGs 280-282 (Acute Myocardial Infarction, Discharged Alive with MCC, with CC, and without CC/MCC, respectively) is assigned. A type 2 myocardial infarction is not a true acute myocardial infarction.
CMS did not agree with changing DRGs 280-282 but did finalize modifications to the GROUPER logic to allow cases reporting diagnosis code I21.A1 (Myocardial infarction type 2) as a secondary diagnosis to group to MS-DRGs 222 and 223 (Cardiac Defibrillator Implant with Cardiac Catheterization with AMI, HF or Shock with and without MCC, respectively) when reported with a listed procedure code for clinical consistency with the other MS-DRGs describing acute myocardial infarction.
MDC 8: Musculoskeletal system: Finalizing to add the three procedure code combinations listed below describing removal and replacement of the right knee joint that were inadvertently omitted from the logic to MS-DRGs 461, 462, 466, 467, and 468 in MDC 08 and MS-DRGs 628, 629, and 630 in MDC 10. They had erroneously mapped to MS-DRG 465 previously. Adding:
0SPC4JC (remove patellar surface) with 0SRV0JZ (Replace tibial surface with synthetic)
0SPT4HZ (remove femoral surface) with 0SRV0JZ (Replace tibial surface with synthetic)
0SPV4JZ (remove tibial surface) with 0SRV0JZ (Replace tibial surface with synthetic)
MDC 16: Blood and Blood Forming Organs: With the finalization of new diagnosis codes T80.82XA (D) (S) Complication of immune effector cellular therapy, initial (subsequent) (sequela) encounter to DRGs 814-816, diagnosis code T80.89XA would no longer be reported and these cases would instead report new diagnosis code T80.82XA, as of October 1, 2021. Therefore, CMS is revising the structure of MS-DRGs 814, 815, and 816 by removing the logic that includes a principal diagnosis of T80.89XA with a secondary diagnosis of any CRS code D89.8- from MS-DRGs 814, 815, and 816 effective FY 2022.
OR to Non-OR and Vice Versa DRG Changes
I will just go over the major changes below.
Procedures performed within the cranial cavity always involve drilling or cutting through the skull regardless of the approach. Therefore the three procedure codes identified cranial cavity procedures are identified by ICD-10-PCS procedure codes 0W310ZZ (Control bleeding in cranial cavity, open approach), 0W313ZZ (Control bleeding in cranial cavity, percutaneous approach) and 0W314ZZ (Control bleeding in cranial cavity, percutaneous endoscopic approach. There CMS is adding the above procedure codes to MDC 01 in MS-DRGs 23, 24, 25, 26, and 27 (“craniotomy” MS-DRGs) for FY 2022 and remove them from assigning to DRGS 981-983 and 987-989.
Many codes were changed from MS-DRGS 981-983 “extensive OR procedures” to MS-DRGS 987-989 “non-extensive” procedures. They include:
- 0JB60ZZ, Excision of chest subcutaneous tissue and fascia, open approach
- 0JB70ZZ, Excision of back subcutaneous tissue and fascia, open approach
- 0JB80ZZ, Excision of abdomen subcutaneous tissue and fascia, open approach
- 31 LITT procedures (D0Y-KZZ, DBY-KZZ, DDY-KZZ, DFY-KZZ, DGY-KZZ, DMY-KZZ, DVY0KZZ) depending on body part were listed as extensive OR procedures.
- Five procedure codes describing repair of esophagus, 0DQ50ZZ, 0DQ53ZZ, 0DQ54ZZ, 0DQ57ZZ, 0DQ58ZZ with PDX from unrelated MDC
- 0T9D0ZZ, Drainage of urethra, open approach
CMS REMOVED 22 procedure codes for drainage of various sies of skin and subcutaneous tissue
as “OR Procedures.” The codes begin with “0J9—-“
Added XW0Q316, Introduction of Eladocagene exuparvovec into cranial cavity and brain,
percutaneous, new technology group 6 as OR procedure and assign them to MS-DRGs 628, 629,
and 630 AND to MS-DRGs 987-989.
0BBN/P0ZX Excision of right or left pleura added as OR procedure for BIOPSY and assigned to
MS-DRGs 166, 167, and 168 (Other Respiratory System O.R. procedures with MCC, CC, without
CC/MCC, respectively)
Adding 02WY3DZ, 03WY3DZ, 04WY3DZ, 05WY3DZ, and 06WY3DZ for percutaneous revision of
various vessel intraluminal device as O.R. procedures to MS-DRGS 270-272 (Other Major
Cardiovascular Procedures, with MCC, with CC, and without CC/MCC, respectively) or 252-254
(Other Vascular Procedures with MCC, with CC, and without CC/MCC, respectively).
Both 0SS7/834Z and 0SS9/B34Z for percutaneous reposition of R/L sacroiliac joint or R/L hip
joint were added as “OR Procedures” and assigned to appropriate MS-DRGS depending on the
principal diagnosis.
Eight procedure codes in 0RP/H—- for Insertion/Removal of spacer in R/L shoulder joint were
added to MS-DRGs 510-512 for Shoulder procedures or MS-DRGs 987-989 for non-extensive OR
procedures.
Four procedure codes 0WC4/5-ZZ for extirpation of matter from upper/lower jaw, open or
percutaneous were added to MS-DRGS 143-145 for ENT OR procedures.
CMS is added 22 procedures, 0JC-0ZZ that describe OPEN extirpation of matter from
subcutaneous tissue and fascia to MS-DRGS 579-581 or 907-909.
Whew!
Other Changes
Surgical hierarchy for MS-DRGS in MDC 05 to sequence MS-DRGs 231-236 (Coronary Bypass) above MS-DRGs 228 and 229.
Several changes were made to the Medicare Code Editor (MCE) to accommodate new code additions.
Unspecified Codes: Currently there are 3,490 unspecified codes. CMS requested public comments on a potential change to the severity level designations for “unspecified” ICD- 10-CM diagnosis codes that CMS had been considering adopting for FY 2022. Instead, the severity level designations were NOT changed, but a new MCE code edit would trigger when an “unspecified” laterality diagnosis code currently designated as either a CC or MCC, that includes other codes available in that code subcategory that further specify the anatomic site, is entered. We refer the reader to table 6P.3a of the Final Rule which lists unspecified diagnosis codes for laterality that would be subject to this edit. This MCE edit will signal to the provider that a more specific code is available to report. CMS believes this edit aligns with documentation improvement efforts and leverages the specificity within ICD-10. The edit will be 10. Unspecified Code Edit. Payment will not be affected but the claim will e returned for review by the provider. The provider will then need to enter “UNABLE TO DET LAT 1” to identify that they are unable to obtain additional information to specify laterality or they may enter “UNABLE TO DET LAT 2” to identify that the physician is clinically unable to determine laterality.”
MCC/CC Severity Levels
CMS decided NOT to change any diagnoses on the MCC list or CC list. Only the expanded (new) codes for FY2022 were added. Coders can review tables 6I.1, 6I.2, 6J.1 and 6J.2 for these additions and deletions.
CMS decided to change some of the CC exclusions for some of the heart failure codes when with I11.0 or I13.2. The full list and changes are contained in the Final Rule AND in HIA’s IPPS Changes for FY2022 education module.
So there you have it for a summary of the IPPS FY2022 changes. Stay tuned….. In the final Part 4 of this series, the New Technology Add-On Payments (NTAP) will be reviewed in detail.
The information contained in this post is valid at the time of posting. Viewers are encouraged to research subsequent official guidance in the areas associated with the topic as they can change rapidly.
Coding Tip: New ICD-10 Codes for FY2023 and Proposed IPPS Rule
Wow, have you seen the proposed rule for FY2023 IPPS yet? There are 1,495 proposed coding changes to ICD-10-CM diagnoses codes alone! There are also some IPPS changes to note. As for ICD-10-PCS, there are not as many new codes, most significantly occlusion of prostate artery and knee joint replacement codes.
Coding Tip: Never-ending Denials
Coding denials are sent after the auditor has reviewed the record in question and the auditor does not agree with the DRG that was paid. This can be for either a diagnosis or a procedure code that they think does not meet reporting requirements.
Introducing HIA’s Cloud-Based Audit Software, Atom Audit, Streamlining Your Coding Auditor’s Workday and Transforming Data into Action
Our new coding audit platform is an easy-to-use and intuitive coding review application, with a customizable reporting dashboard, that enables auditors to efficiently and effectively manage the entire audit lifecycle.
Coding Tip: New ICD-10 Codes and IPPS Changes for April 1, 2022
As of April 1, 2022 discharges, the following changes in ICD-10 and IPPS will be implemented. For years the coding community did not see changes occurring in April of the fiscal year. HIM professionals were used to not even worrying about April changes. This year, we do have some significant code additions and a change in the IPPS CC/MCC edit. The ICD10MCE and Grouper Version will be 39.1.
Part 10: Most Common DRG’s with Recommendations – DRG 190
DRG 190 (Chronic obstructive pulmonary disease with MCC) was the number 10 most common DRG with recommendations from HIA in 2021.
Part 9: Most Common DRG’s with Recommendations – DRG 640
DRG 640 (Miscellaneous disorders of nutrition, metabolism, fluids, and electrolytes with MCC) was the number 9 most common DRG with recommendations from HIA in 2021.
Part 8: Most Common DRG’s with Recommendations – DRG 981/982
DRG 981 (Extensive O.R Procedures unrelated to principal diagnosis with MCC) was the number 8 most common DRG with recommendations from HIA in 2021.
Part 7: Most Common DRG’s with Recommendations – DRG 682
DRG 682 (Renal failure with MCC) was on of the most common DRG with recommendations. Renal failure can either be a chronic or acute condition.
Part 6: Most Common DRG’s with Recommendations – DRG 793/794
DRG 793 (Full term neonate with major problems and DRG 794 (Neonate with other significant problems) are reported together.
Part 5: Most Common DRG’s with Recommendations – DRG 193
DRG 193 (Simple pneumonia and pleurisy with MCC). DRG 193 seems to always be in the top 5 and a focus for denials.
Part 4: Most Common DRG’s with Recommendations – DRG 189
DRG 189 (Pulmonary edema and respiratory failure). This should be no surprise to coders that DRG 189 is in the top DRG’s with recommendation.
Part 3: Most Common DRG’s with Recommendations – DRG 291
DRG 291 (Heart failure with shock with MCC). This should be no surprise to coders that DRG 291 is in the top DRG’s with recommendation. It seems to always be in the top 5 and a focus for denials.
Part 2: Most Common DRG’s with Recommendations – DRG 177/178
DRG 177 (Respiratory infections and inflammations with MCC) and 178 (Respiratory infections and inflammations with CC). This should be no surprise to coders that DRG 177 is in the top DRG’s with recommendation.
Part 1: Most Common DRG’s with Recommendations – DRG 871
Sepsis is and will most likely always be a troubled area for coders. There are multiple reasons for this and we will look at a few of these. There are many different criteria being used to validate the diagnosis of sepsis.
Coding Tip: Common Errors Found in Anterior and Posterior Spinal Fusion Coding for Hospitals
During a recent review of spinal fusion cases at a client, we found coding issues on the cases in which both an anterior interbody fusion, anterior open approach was done on one day and two days later, the patient was brought back for a posterior fusion, posterior open approach. Below are some of the recommendations we made along with education explanations.
Part 5: New 2022 CPT Codes – Modifiers, Category III codes, Evaluation and Management, etc.
This is Part 5 of a five part series on the new 2022 CPT codes. For the remaining areas we will just briefly summarize the section. Due to the intricate nature of these sections in CPT, it is recommended that the coder read the entire section notes associated with the new codes.
Part 4: New 2022 CPT Codes – Nervous, Ocular and Auditory Systems
This is Part 4 of a 5 part series on the new 2022 CPT codes. In this one we will explore the nervous, ocular and auditory systems CPT changes.
Part 3: New 2022 CPT Codes – Digestive, Urinary and Reproductive Systems
This is Part 3 of a 5 part series on the new 2022 CPT codes. In this one we will explore the digestive, urinary and reproductive system CPT changes.
Part 2: New 2022 CPT Codes – Cardiovascular System
This is Part 2 of a five part series on the new 2022 CPT codes. In this series we include examples to help the coder understand the new codes.
Part 1: New 2022 CPT Codes – Integumentary, Musculoskeletal Systems
This is Part 1 of a five part series on the new 2022 CPT codes. In this series we include examples to help the coder understand the new codes.
Home Alone ICD-10 Codes
10 ICD-10 Codes from the Christmas movie Home Alone. T20. 10XA for Harry, Burn of first degree of head, face, and neck, unspecified site, initial encounter. T20.56XA for Kevin and his aftershave incident, Corrosion of first degree of forehead and cheek, initial encounter.
Coding Tip: New COVID Vaccine Codes
CMS released seven new procedure codes related to the introduction or infusion of therapeutics, including vaccines for COVID-19 treatments.
Coding Tip: New 2022 CPT Codes
There are a total of 249 new, 63 deleted and 93 revised CPT codes for 2022. That brings the total number of CPT codes to 10,819 per the AMA.
Coding Tip: FY2022 IPPS Final Rule and Unspecified Laterality Diagnosis Codes
Did you get a chance to read the FY2022 IPPS Final Rule? There is an interesting topic that was discussed regarding unspecified ICD-10-CM laterality diagnosis codes, to be exact. In this coding tip we discuss that subject and possible ramifications of it in the coding world.
Part 4: New 2022 Technology Add-On Payments (NTAP)
In Part 4 of the series, we will review the NTAP procedure codes and reimbursement add-on payments. Prepare yourself as this is rather lengthy due to continuation of NTAP that would normally expire.
Coding Tip: AHA COVID FAQs for ICD-10-PCS & New Technology
Coders are instructed, at this time, to follow the AHA Frequently Asked Questions Regarding ICD-10-CM/PCS Coding for COVID-19. Lately, we have seen missing PCS codes for the new technology drugs that were introduced on August 1, 2020 and thereafter.
Part 2: New 2022 ICD-10-PCS Procedure Code Changes
This is Part 2 of a 4 part series on the FY2022 ICD-10 Code and IPPS changes. In this part, the ICD-10-PCS procedure codes are presented.
Part 1: New 2022 ICD-10-CM Codes
This is Part 1 of a 4 part series on the FY2022 changes to ICD-10 and the IPPS. In this part, we discuss some of the new ICD-10-CM diagnosis codes and changes.
Coding Tip: Chronic Subsegmental Pulmonary Emboli – One Code or Two?
With the creation and implementation of ICD-10-CM, multiple codes are available to describe the type of pulmonary emboli that occur.