2018 IPPS final rule updates ICD-10-PCS non-OR to OR designations

The fiscal year (FY) 2018 IPPS final rule included updates to payment rates and quality initiatives, as well as an ample amount of code changes and updates to ICD-10-PCS non-operating room (OR) to OR code designations.

According to CMS, several commenters disagreed with the proposed non-OR designations for certain procedure codes displayed in the proposed rule and asked that they be revisited in the final rule.

The commenters identified approximately 200 new procedure codes describing the Insertion, Removal, or Revision of “other devices” in various body parts that they stated require an OR setting or are most often performed in the OR setting using sterile technique, the final rule said. Commenters also stated that patients undergoing these procedures are placed under general anesthesia and the procedures require significant time and skill.

In response, CMS reexamined a portion of the procedure codes under question. CMS noted that it was unable to fully reevaluate the complete list for FY 2018 but plan to conduct a full review for FY 2019.

After consideration of the public comments, and upon further examination of whether these procedures would be performed in an OR setting, CMS said it is finalizing the designation of the following numerous procedure codes from non-OR to OR, effective October 1. For the full list, see page 290 of the final rule.

Historically, when new procedure codes were created for ICD-10-PCS, they were to be given the same OR designation as their predecessor ICD-9-CM Vol. 3 code. However, with the transition from ICD-9-CM to ICD-10-PCS, the determination has become a much more complex task due in part to the number of various approaches available in the ICD-10-PCS classification, CMS said.

Due to this complexity, CMS is soliciting comments on what factors or criteria should be considered when determining whether a procedure should be designated as an OR procedure.

CMS encourages comments via the CMS MS-DRG Classification Change Requests Mailbox at MSDRGClassificationChange@cms.hhs.gov by November 1 for FY 2019 consideration.

To learn more about the provisions in the 2018 IPPS final rule, join HCPro regulatory specialist Valerie Rinkle, MPA, for her presentation at this year’s Revenue Integrity Symposium on October 23 and 24. Click here to sign up or view a full agenda.