News: ACDIS Regulatory Committee submits comments on FY 2021 IPPS proposal

The ACDIS CDI Regulatory Committee recently submitted comments to CMS on behalf of the ACDIS membership regarding the fiscal year (FY) 2021 inpatient prospective payment system (IPPS) proposed rule.

Their recommendations specifically center around the designation of the proposed cytokine release syndrome (CRS) codes as non-CC/MCCs. While none of the CRS codes have proposed CC/MCC statuses, the committee feels that CRS grades 3, 4, and 5 because in these cases “the provider is treating a complicated patient with major comorbid conditions that require resource use.

CMS outlined their methodology for assigning CC/MCC status in the FY 2021 IPPS proposal and the Regulatory Committee believes that CRS grades 3, 4, and 5 meet seven out of the nine severity criteria set forth by the proposed rule.

In addition to the re-designation as CC/MCCs, the Regulatory Committee requested that CMS expand the CRS coding logic to include the COVID-19 patient population as it is a common occurrence in the advanced COVID-19 patient population.

The Regulatory Committee encourages CDI professionals to review the letter for themselves and use it as a template for submitting individual comments to CMS regarding this topic.