Hi, CMS has posted a Final Rule relative to:
Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program and Value-Based Purchasing Program for Federal Fiscal Year 2020
This document is scheduled to be published in the Federal Register on 08/07/2019 and available online at https://federalregister.gov/d/2019-16485, and on govinfo.gov
I have attached a PDF.Any assistance in interpretation would be greatly appreciated!
There are 76 references to ICD-10 in the 364 pages, here is some of the flavor:
Comment: Some commenters commented on an aspect of the PDPM established in the
FY 2019 SNF PPS final rule (83 FR 39162), specifically, the use of ICD-10 codes in section
I0020B to assign patients to clinical categories used for categorization in the PT, OT, and SLP
components. Commenters noted a possible discrepancy between the American Health
Information Management Association (AHIMA) guidance and MDS guidance with regard to
how to code the "principal diagnosis" in I0020B. Commenters requested that CMS work with
AHIMA or other professional coding organizations to ensure that coding instructions for the
MDS are consistent with all relevant ICD-10 coding rules and guidelines.
Response: We appreciate these comments and will work to ensure that any guidance
provided to SNFs on ICD-10 coding practice aligns with best practices in this field.
Comment: A commenter encouraged CMS to ensure that, for SNFs, the subregulatory
process to update ICD-10 mappings and lists aligns with the process used in the context of the
Inpatient Rehabilitation Facility (IRF) PPS, where the commenter understands providers globally
have accepted the changes.
Response: We agree and believe the proposed subregulatory update process for SNFs
aligns with the process used in the IRF PPS to update the tier comorbidities list and the code lists
used for the IRF presumptive compliance methodology. As we noted in the proposed rule, the
subregulatory update process used in the IRF PPS was one of the models we used to develop the
proposed subregulatory process for updating ICD-10 code mappings and lists in the SNF PDPM.
Comment: A commenter noted that, in addition to annual implementation of new and
revised ICD-10-CM codes, the conventions and instructional notes in the ICD-10-CM code set
and the ICD-10-CM Official Guidelines for Coding and Reporting are also updated on October 1
of each year. The commenter stated that compliance with the current ICD-10-CM codes,
conventions, instructions, and the Official Guidelines for Coding and Reporting is required for
all healthcare settings under the Health Insurance Portability and Accountability Act (HIPAA).
The commenter recommends that CMS ensure any appropriate updates to the ICD-10-CM codes
associated with PDPM clinical categories and comorbidity lists that are necessitated by changes
to the ICD-10-CM conventions, instructions, or guidelines are included in the proposed
Response: We agree and will ensure that any appropriate updates to the ICD-10-CM
codes associated with PDPM clinical categories and comorbidity lists that are necessitated by
changes to the ICD-10-CM conventions, instructions, or guidelines are included in the proposed
subregulatory update process.
Comment: Some commenters provided specific recommendations on revisions to the
current mappings available on the CMS website, such as changes in code assignments to clinical
categories and the comorbidities list, additional comorbidities, and other such changes.
Response: We appreciate the commenters' suggestions for changes in the current ICD-10
mappings and lists. However, because we consider these suggestions to be outside the scope of
the current rulemaking, we are not addressing them in this final rule. We will certainly consider
these suggestions as part of our future rulemaking efforts, or for inclusion in our updated
mappings in case certain suggestions may be characterized as non-substantive in nature.
After consideration of the comments received, for the reasons discussed in this final rule
and in the FY 2020 SNF PPS proposed rule, we are finalizing as proposed, without modification,
the process discussed above for updating the ICD-10 code mappings and lists associated with
PDPM. As proposed, the subregulatory process for updating the ICD-10 codes used under the
PDPM will take effect beginning with the updates for FY 2020. When the proposed rule was
issued, the ICD-10 code mappings and lists available for download from the SNF PPS Web site
reflected the adoption of the ICD–10 Coordination and Maintenance Committee's draft changes
to the ICD–10 medical code data sets, effective October 1, 2018, and we stated that these would
constitute the baseline for any future updates to the mappings and lists using the update process
finalized in this rule. Effective October 1, 2019, these baseline mappings and lists will be
updated to incorporate, as appropriate under the process finalized in this rule, updates to the
ICD-10 code sets issued by the ICD–10 Coordination and Maintenance Committee in June 2019
to be effective October 1, 2019. We plan to post these updated mappings and lists on our
website prior to October 1, 2019 (and after issuance of this final rule) so that the public can
access them prior to the effective date