The Unspecified Exodus!
When teaching coders, I always try to stress using the unspecified codes as your last choice – only used when all else fails. There are certain unspecified codes that should almost NEVER be used, especially in the inpatient setting, and CMS is going to help us quit using them!
In the FY 2022 Proposed Rule, CMS recommended removing the MCC/CC designations for unspecified diagnoses where there is a more specific anatomical site code available in that subcategory. Now that was going to be a direct hit to the pocketbook! After receiving a lot of public comment, CMS decided not to implement that for FY 2022; however, they did finalize a new Medicare Code Editor (MCE) 20. Unspecified code, to be implemented April 1, 2022, with the grouper Version 39.1.
There are a few places where you can find the 3,432 unspecified codes that will trigger this new edit. One is on Table 6P.3a from the IPPS FY 2022, found here: Table 6P.3a. Another place is the MS-DRG Definitions Manual and Software found here: Definition of Medicare Code Edits V39.1. All inpatient coders and clinical documentation practitioners should pay close attention to this new edit. Shall we say that it’s likely a precursor of things to come!
Per the Definitions document:
“Unspecified codes exist in the ICD-10-CM classification for circumstances when documentation in the medical record does not provide the level of detail needed to support reporting a more specific code. However, in the inpatient setting, there should generally be very limited and rare circumstances for which the laterality (right, left, bilateral) of a condition is unable to be documented and reported.”
In my opinion, finalizing this new MCE is an indication that CMS is likely to follow through with removing the MCC/CC designations from these 3,432 codes once we have made preparation to guard against unexpected deficits in revenue. Now is the time to GET READY FOR IT! Educate your providers and use queries when appropriate to reinforce the need to document laterality at all times. If we fail to do this, then we will be blindsided with decreased revenue when the rule is finalized. It’s seems inevitable.
Act now - before CMS pulls the plug and this MCC/CC reimbursement goes down the drain!
Katherine Isbell, RHIA, CDIP, CCS, AHIMA-Approved ICD-10-CM/PCS Trainer
LexiCode Education Services Manager