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    SCAI Response to CMS’s 2020 IPPS Proposed Rule

    June 24, 2019

    SCAI submitted comments to the Centers for Medicare & Medicaid Services (CMS) on Monday, June 24, 2019, in response to the 2020 Inpatient Prospective Payment System (IPPS) proposed rule. The comments strongly urged CMS to vacate their plans to make sweeping changes to major complications or comorbidities (MCC) and complications and comorbidity (CC) severity levels, downgrading the severity of hundreds and hundreds of conditions including many conditions treated by SCAI members (e.g., STEMI, heart failure, cardiac arrest, etc.).

    SCAI found that many of the proposed changes would result in clinically nonsensical statuses that if enacted, would have a negative financial impact on hospitals. SCAI also asked CMS to hold the current 2019 reimbursement level for DRG 215 that includes pVADs, a diagnosis-related group (DRG) that has seen continued erosion in the reimbursement rate over the past few years believed to be due to changes in coding for these procedures.

    SCAI applauded CMS for finally moving TMVR into an appropriate DRG grouping alongside other transcatheter valve procedures. SCAI also included a recommendation to CMS that more granular valve DRGs for multi-valve/multi-device transcatheter valve procedures may be needed in the near future. SCAI thanked CMS for changes to the new tech add-on payment rate and approval process. We expressed appreciation for CMS moving peripheral ECMO ICD-10 procedural codes to a cardiovascular bucket. For 2019, the venous-venous peripheral ECMO code had been placed in a non-cardiovascular bucket negatively impacting hospital reimbursement for these procedures. Finally, we advised CMS that SCAI believes TherOx’s SSO2 meets the new tech add-on criteria. To read SCAI’s comments in their entirety, click here.