The ACC has submitted formal comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed FY 2020 Medicare Hospital Inpatient Prospective Payment System (IPPS) rule. The comments focus on several changes to medical severity diagnosis related groups (MS-DRGs), as well as several health IT proposals and requests for information.

As part of the comment letter, ACC stresses its opposition to CMS' proposal to reassign 13 ICD-10-CM diagnosis codes for acute myocardial infarction and subsequent ST elevation myocardial infarction (STEMI) from severity designation MCC to CC. CMS had noted in the proposed rule that "patients with a secondary diagnosis of myocardial infarction may require additional diagnostic imaging, monitoring, medications, and additional interventions, thereby consuming resources that are consistent with CC status."

However, the letter urges CMS not to finalize this change and take resources away from MI patients. Similarly, the ACC comments also recommend that CMS not finalize the reassignment of three ICD-10-CM diagnosis codes for congestive heart failure (CHF) from severity designation CC to Non-CC.

The ACC comments do support the CMS proposal to reassign the codes for peripheral ECMO (5A1522G and 5A1522H) to Pre-MDC MS-DRG 003, noting that "this change recognizes that method of cannulation should not drive assignment." The College also recommends that CMS finalize its proposal to modify the structure of MS-DRGs 266 and 267 and reassign procedure codes describing a transcatheter cardiac valve repair (supplement) procedure to the newly modified MS-DRGs.

Interoperability and health information technology (IT) are also addressed in the ACC's comments. Of note, the ACC thanks CMS for continuing to provide a 90-day reporting period for new and continuing participants in the Promoting Interoperability Program. Additionally, the ACC shares its support for the inclusion of functionality-based criteria such as usability and user-centered design into the Promoting Interoperability Conditions and Maintenance of Certification process.

The importance of considering the inclusion of user-reported criteria is also highlighted, noting that "usability and interoperability will only improve when clinicians can provide feedback to ONC and Health IT Vendors that will directly contribute to the certification and maintenance of an EHR system."

The College also urges transparency regarding real-world testing performed on certified health IT systems and encourages "CMS to consider methods to promote technical solutions or approaches for capturing patient-generated health data and incorporating it into CEHRT using standards-based approaches."

Patient matching is another area of focus, with CMS, Congress and others indicating that accurate patient matching solutions are important to achieving true interoperability and the development of automated and seamless data transmissions. However, ACC cautions that patient matching errors can be costly and dangerous.

"The recently proposed ONC and CMS rules will help to improve patient matching through defined standardized data elements, the creation of a standard version advancement process, requiring real world testing for certified health IT and the mandated use of API technology," the ACC writes. "The College thanks CMS and ONC for taking these steps and encourages the continued emphasis of the importance of patient matching solutions as technological advances continue."

Read the complete comment letter here.

Keywords: Humans, Myocardial Infarction, Centers for Medicare and Medicaid Services, U.S., International Classification of Diseases, Inpatients, Data Mining, Medicare, Medicaid, Prospective Payment System, Diagnosis-Related Groups, Certification, Heart Failure, Medical Informatics, Catheterization, Diagnostic Imaging, Heart Valves, ACC Advocacy

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