CC/MCC Analysis - What’s in Store?

Scot Nemchik, Vice President of Coding Education

Over the past few years, CMS has made known their intent to perform a comprehensive CC/MCC analysis to assess the appropriateness of each diagnosis codes ‘CC severity’.  CC severity is the term used to describe a codes role as a DRG influencer in the inpatient prospective payment system.  We know these roles to be MCCs (Major Complication and Comorbidity), CCs (Complication and Comorbidity) and non-CCs, the category reserved for codes that are neither MCCs nor CCs.  The FY 2018 IPPS Proposed Rule, released on May 7th, 2018, takes it a step further and confirms that the comprehensive CC/MCC analysis is in fact underway.  Gulp.  It’s worth noting that the methodology CMS is using to analyze is the same methodology they used to categorize CCs and MCCs in the first place.  For more information on the process, feel free to peruse section “Overview of Comprehensive CC/MCC Analysis” in Proposed Rule CMS-1694-P.

So much has changed since the initial diagnosis code CC severity classification in 2007, not the least of which was the implementation of ICD-10-CM, a new diagnosis code set five times larger than its predecessor…which has grown by 2000 codes in the past three years.  In this same time span, we’ve witnessed the explosion of, and most likely participate in clinical documentation improvement initiatives.  Organizations have created departments and mobilized teams with the sole purpose of optimizing provider documentation for various means including reimbursement, and more recently, indicators of clinical efficacy and healthcare quality rankings.  Nowadays CDI is as familiar an acronym as CMI.

It goes without saying that the CC/MCC designation are critically important to the CDI industry.  A sweeping analysis which stands to affect the CC/MCC designation of over 17,000 codes gives us good reason to follow any developments closely and to prepare ourselves to mobilize around the outcomes.  The idea that we may have to revise CDI talking tracks for provider discussions, possibly even develop new ones, is a distinct possibility indeed.  The idea that we will be able to end the CDI hot pursuit of certain diagnoses exists as well, and for some codes who shall remain nameless, it would be good riddance.

Until then, it’s wait and see, or maybe wait and hope; hope that the results of the analysis don’t turn our coding/CDI world upside down.  In the meantime, it’s probably a good idea to let coders and CDI staff alike know that CMS is spending their summer doing some serious CC/MCC number crunching.