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3M Health Information Systems, Inc.
© 2007 3M Health Information Systems, Inc. All Rights Reserved.
Assessing the Financial Impact of MS-DRGsHealthcare Financial Management Association-Utah ChapterSeptember 20, 2007
2© 2007 3M Health Information Systems, Inc. All Rights Reserved.
3M Health Information Systems, Inc.
Major Changes Proposed in the Final Rule
DRG Reclassification and Relative Weight Recalibration Medicare Severity DRGs (MS-DRGs) Hospital-acquired Conditions (per the Deficit Reduction Act) Relative Weight Modifications Behavioral Offset Update to Long Term Care DRGs
Updates to payment related changes including: Wage Index Operating and GME costs Capital related costs Rates for excluded hospitals Operating and Capital Rates
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October 1, 2007
MS-DRGs will be used for IPPS
New DRGs New reimbursement POA and other regulatory
changes
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How does a grouper work?
It is similar to a known recipe:
+ + =
Identification of diagnoses and procedures
Coding the diagnoses and procedures
Grouping the diagnoses and procedures
DRG
5© 2007 3M Health Information Systems, Inc. All Rights Reserved.
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What’s driving severity documentation and coding today?
Severity based reimbursement: changes in hospital payment by Medicare, Medicaid, and private payers
Provider profiling and performance transparency: Patients are “sicker” and we need to demonstrate how this impacts our ability to deliver quality care
Hospital report cards: Consumers want to compare providers (and have more methods to do so today)
Aging population and increasing life expectancy: the need to conserve limited resources for increasing demand
Quality focused care: providers need ways to measure and improve their performance
6© 2007 3M Health Information Systems, Inc. All Rights Reserved.
3M Health Information Systems, Inc.
7© 2007 3M Health Information Systems, Inc. All Rights Reserved.
3M Health Information Systems, Inc.
© 3M 2007. All rights reserved.
Key Regulatory Changes:
Regulation:
Provider Implications
Must learn new DRG system Must learn new CC and MCC
lists Must be ready by October 1
Creates Major CC subclasses Increases number of DRGs
from 538 to 745 Completely revised CC list
CMS adopts MS-DRGs:
8© 2007 3M Health Information Systems, Inc. All Rights Reserved.
3M Health Information Systems, Inc.
© 3M 2007. All rights reserved.
What are MS-DRGs?
Update to 1994 Severity DRGs 3 Step Process:
Consolidate current DRGs into base DRGs Categorize each diagnosis as:
• Major CC (MCC)• CC• Non-CC
Subdivide each base DRG into subgroups based on CCs• No Subgroups• 3 groups (MCC, CC, non-CC)• 2 groups (MCC/CC, non-CC)• 2 groups (MCC, CC/non-CC)
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Consolidation of DRGs:
115 pairs of DRGs that were subdivided based on presence of a CC
Major cardiovascular conditions 3 pairs of burn DRGs 43 pediatric DRGs that were defined by age <=17 Several DRGs relating primarily to pediatric or adult population that
have very low volume in the Medicare population Several elective surgery DRGs that have shifted to outpatient
settings Some clinically related DRGs that had volume, but no difference in
resource use MDC 14 & 15 were not consolidated due to low volume
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MS DRGs Increases the Number of DRGs from 538 to 745
SubgroupsNumber of Proposed
Base MS-DRGs
Number of Proposed MS-DRGs
No Subgroups 53 53
Three subgroups 152 456
Two subgroups: major CC and CC; non-CC 43 86
Two subgroups: non-CC and CC; major CC 63 126
Subtotal 311 721
MDC 14, 15 22 22
Error DRGs 2 2
Total 335 745
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MS vs. current CMS DRG Groups:Base Group, no splits
CMS V24 CMS DRG Descriptions MS v25 MS-DRG Descriptions 524 Transient ischemia 069 Transient ischemia
MS vs. current CMS DRG Groups:3 Groups - MCC, CC, non-CC
CMS V24 CMS DRG Descriptions MS v25 MS-DRG Descriptions 027 Traumatic Stupor & Coma,
coma > 1 hr082 Traumatic stupor & coma, coma >1
hr w MCC083 Traumatic stupor & coma, coma >1
hr w CC084 Traumatic stupor & coma, coma >1
hr w/o CC/MCC
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© 3M 2007. All rights reserved.
MS vs. current CMS DRG Groups:2 Groups – with MCC, without MCC
CMS V24 CMS DRG Descriptions MS v25 MS-DRG Descriptions 103 Heart transplant or implant of
heart assist system001 Heart transplant or implant of heart
assist system w MCC002 Heart transplant or implant of heart
assist system w/o MCC
MS vs. current CMS DRG Groups:2 Groups – with CC/MCC, without CC/MCC
CMS V24 CMS DRG Descriptions MS v25 MS-DRG Descriptions 021 Viral meningitis 075 Viral meningitis w CC/MCC
076 Viral meningitis w/o CC/MCC
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© 3M 2007. All rights reserved.
MS vs. current CMS DRG Groups:Exception to rules:
CMS V24 CMS DRG Descriptions MS v25 MS-DRG Descriptions 480 Liver and/or Intestinal
Transplant005 Liver transplant w MCC or intestinal
transplant006 Liver transplant w/o MCC
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© 3M 2007. All rights reserved.
Key Regulatory Changes:
Regulation:
Provider Implications
Behavioral offset:
CMS anticipates improved documentation and coding
Payments reduced 1.2% to account for this
Blending of relative weights MS-DRGs and CMS DRGs
Unless documentation and coding is improved a significant loss of payment will occur impacting operating margins
15© 2007 3M Health Information Systems, Inc. All Rights Reserved.
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Behavioral Offset
Proposed Rule was 2.4% in FY2008 and FY2009 Final Rule is 1.2% in FY2008 and 1.8% in FY2009
and FY2010 This compromise to the proposed rule includes a 2
year phase in of the impact of MS-DRGs by blending the relative weights 50% base on CMS DRGs and 50% based on MS-DRGs
16© 2007 3M Health Information Systems, Inc. All Rights Reserved.
3M Health Information Systems, Inc.
© 3M 2007. All rights reserved.
Key Regulatory Changes:
Regulation:
Provider Implications
MS-DRGs are designed for payment of Medicare
patients:
Not applicable to other payers Not applicable for quality
Other payers will likely adopt other groupers
Hospitals need to maintain multiple groupers
17© 2007 3M Health Information Systems, Inc. All Rights Reserved.
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IPPS Applicability
“The focus of CMS’ efforts is in developing and maintaining a DRG system that is appropriate for its Medicare population.”
“We do not believe that Medicare should undertake the effort and expense to maintain and update a DRG system that will have no application for Medicare beneficiaries.”
18© 2007 3M Health Information Systems, Inc. All Rights Reserved.
3M Health Information Systems, Inc.
© 3M 2007. All rights reserved.
Key Regulatory Changes:
Regulation:
Provider Implications
Payment weight methodology modified:
Second year of three year transition to cost based weights
Impact on aggregate payments will vary by hospital
Relative profitability across service line will change
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© 3M 2007. All rights reserved.
Relative Weights
CMS will continue to implement the cost-based DRG relative weights under the 3-year transition period that began in FY2007
This year the relative weights will be recalibrated using a blend of 67 percent of the cost relative weight and 33 percent of the charge relative weight
By FY 2009, the relative weights will be 100 percent cost-based
The 50/50% blend of MS-DRGs and CMS DRGs in calculating the relative weight is on top of the transition to cost based weights
20© 2007 3M Health Information Systems, Inc. All Rights Reserved.
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© 3M 2007. All rights reserved.
Key Regulatory Changes:
Regulation:
Provider Implications
Present on Admission Indicator (POA):
New POA data element must be submitted to Medicare
Must begin coding POA Coder productivity will be
impacted
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© 3M 2007. All rights reserved.
Deficit Reduction Act Requirements
Deficit Reduction Act (DRA)—(Pub. L. 109-171) Requires that the Present on Admission (POA) indicator be
collected for all Medicare patients— beginning Oct 1, 2007 Requires CMS to select two or more conditions that are high
cost/high volume. Requires CMS to begin excluding those conditions from the
calculation of the DRG when they are identified as not present on admission—beginning Oct 1, 2008.
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© 3M 2007. All rights reserved.
Implementation Date for POA Data Collection
Deficit Reduction Act of 2005 (DRA) requires the POA indicator to be collected starting Oct. 1, 2007
Change Request #5499 instructs hospitals how to submit this data Current Form ASC X12N 837, v4010 does not have POA field Segment K3 in the 2300 loop, data element K301 should be
used Instructions on how to code the POA indicator are in the ICD-
9-CM Official Guidelines for Coding and Reporting
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Key Regulatory Changes:
Regulation:
Provider Implications
8 Post admission complications excluded from DRG assignment:
Post admission complications excluded from DRG assignment
Model potential financial impact and initiate continual improvement measures
Evaluate post admission complication rates in your facility
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3M Health Information Systems, Inc.Hospital-Acquired Conditions not POA will not be included in MS DRG assignment beginning October 2008
Condition Considered in NPRM
Proposed in NPRM
Selected in FY 2008 Final Rule
May Be Considered in
Future Rulemaking
1. Serious Preventable Event- Object left in surgery
Yes Yes Yes N/A
2. Serious Preventable Event- Air embolism
Yes Yes Yes N/A
3. Serious Preventable Event- Blood incompatibility Yes Yes Yes N/A
4. Catheter Associated Urinary Tract Infections
Yes Yes Yes N/A
5. Pressure Ulcers (Decubitus Ulcers) Yes Yes Yes N/A
6. Vascular Catheter Associated Infection Yes No (No FY 2008
code)
Yes (Code Created for FY
2008) N/A
7. Surgical Site Infection-Mediastinitis after Coronary Artery Bypass Graft (CABG) surgery
Yes (All surgical site infections, not just Mediastinitis) No (No unique
codes)
Yes (Comments suggested
Mediastinitis which has unique
code)
N/A
8. Falls Yes No (Coding not unique)
Yes (Operational difficulties will be overcome by
FY 2009)
Expand to all hospital acquired injuries, adverse events
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Summary
Regulation Provider ImplicationsCMS adopts MS-DRGs on October 1,2007 Learn new DRG system, new CC and MCC lists
Ensure software solutions are MS DRG ready
Educate cross functional team on MS DRGs
1.2% Behavioral Offset in anticipation of coding and documentation improvement
Educate HIM department about MS DRG coding implications
Ensure most accurate documentation and coding processes in place
MS-DRGs are designed for payment of Medicare patients: Other payers will likely adopt other groupers
Hospitals need to maintain multiple groupers
Continued transition from charge to cost based relative weights Analyze gap and impact analysis
Ensure software systems are ready for reimbursement calculations
Submit Present on Admission (POA) data to Medicare Ensure software tools are ready for POA collection
Educate HIM department on POA coding guidelines
Consider operational improvements for coder workflow
8 Post Admission complications identified for exclusion from DRG assignment (October 1, 2008)
Model potential financial impact, gap and initiate continual improvement measures.
Evaluate post admission complication rates in your facility.
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Financial Changes in the next three years
2008 2009 2010
Behavioral offset
1.2% 1.8% 1.8%
Cost vs charge
67/33 100% 100%
Complication not calculated in DRG
0% impact If not POA, not calculated
If not POA, not calculated
CMS/MS DRG weight blend
50/50 50/50 Full MS DRG
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Complications/Comorbidities
Major CCs (MCC) were designated if: they were a CC for CMS, they were a Major CC in AP-DRGs they were an APR DRG severity 3 (major) or severity 4 (extensive)
Non-CC: non-CC diagnosis in CMS and in AP-DRGs APR DRG default severity level 1 (minor)
CC: any diagnosis that did not meet either of the above two criteria
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Summary of 3M™ APR DRGs
MDC/APR MDC
Subdivide each APR DRG
into subclasses
Four Severity of Illness Subclasses
1. Minor
2. Moderate
3. Major
4. Extreme
Four Risk of Mortality Subclasses
1. Minor
2. Moderate
3. Major
4. Extreme
316 APR DRGs
1,258 Subclass Cells 1,258 Subclass Cells
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Examples of 3M™ APR DRG Subclasses
Risk of Mortality Secondary Diagnosis-Cardiac Dysrhythmias1 Minor Premature Beats 2 Moderate Sinoatrial Node Dysfunction 3 Major Paroxysmal Ventricular Tachycardia 4 Extreme Ventricular Fibrillation
Severity of Illness Secondary Diagnosis-Diabetes Mellitus1 Minor Uncomplicated Diabetes 2 Moderate Diabetes w Renal Manifestation 3 Major Diabetes w Ketoacidosis4 Extreme Diabetes w Hyperosmolar Coma
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Complications/Comorbidities Reduced CC list from 3,326 to 2,583 diagnoses codes in 2006; now there are
4,922 codes that are either a Major CC or a CC: Major CC 1,580 codes CC 3,342 codes
Patients under V 24 had at least one CC 77.6% of the time, under the proposed MS-DRG system, this will be reduced to 40.34%.
Chronic diseases were removed from the CC list unless there was a significant acute manifestation: Mitral valve disorders CHF Stage I-II chronic renal failure Chronic UTI
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MS-DRG Categories
MS-DRGs with no qualifiers Chest Pain
Chest PainCMS DRG 143
RW .5637$2,749 Chest Pain
MS-DRG 313RW .5550
$2,707
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MS-DRG Categories
MS-DRGs with 3 potential groups (MCC-CC-NCC)
Congestive Heart Failure(No qualifiers required)
CMS DRG 127RW 1.0490
$5,117
MS-DRG 291Heart Failure w MCC
RW 1.4760$ 7,200
MS-DRG 292 Heart Failure w CC
RW 1.0169$4,960
MS-DRG 293 Heart Failure w/o MCC or CC
RW .7265$3,544
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MS-DRG Categories
MS-DRGs with MCC or w/o MCC
CABG with Cath w Major CVCMS DRG 547
RW 6.1390$29,946
CABG with Cath w MCCMS-DRG 233RW 7.1350
$34,805
CABG with Cath w/o MCCMS-DRG 234RW 4.6211
$22,542
CABG with Cath w/o Major CVCMS DRG 548
RW 4.6440$22,653
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MS-DRG Categories
MS-DRGs with CC/MCC or w/o CC/MCC
Major Joint/Limb Reattachment UE
CMS DRG 491RW 1.7203
$8,392
Major Joint/Limb Reattachment UE w CC/MCCMS-DRG 483RW 2.1931
$10,698
Major Joint/Limb Reattachment UE w/o CC/MCCMS-DRG 484RW 1.6862
$8,225
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MS-DRGs Demand Increased Coding Precision
“In determining the CC subclass assigned to a diagnosis, imprecise codes were, in general, not assigned to the MCC or CC subclass.”
Non CCHeart Failure NOS 428.9
Non CCCongestive Heart Failure NOS428.0
CCSystolic & Diastolic Heart Failure428.40
CCChronic Diastolic Heart Failure428.32
CCChronic Systolic Heart Failure428.22
CCSystolic Heart Failure NOS428.20
CCLeft Heart Failure428.1
Major CCAcute On Chronic Diastolic Heart Failure428.33
Major CCAcute Diastolic Heart Failure428.31
Major CCAcute On Chronic Systolic Heart Fail428.43
Major CCAcute Systolic & Diastolic Heart Failure428.41
Major CCAcute Systolic Heart Failure428.21
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Why is documentation and coding improvement so critical?Example: In MS DRGs the precise type of heart failure dramatically impacts payment
In prior versions of the CMS DRGs all heart failure codes were a CC so distinctions related to the type of heart failure did not impact DRG assignment
428.1 Left Heart Failure
428.20 Systolic Heart Failure NOS
428.22 Chronic Systolic Heart Failure
428.30 Unspecified Diastolic Heart Failure
428.32 Chronic Diastolic Heart Failure
428.40 Systolic & Diastolic Heart Failure
428.42 Chronic combined Systolic and Diastolic Heart Failure
With MCCWith CCWithout CC or MCC
428.21 Acute Systolic Heart Failure
428.23 Acute on Chronic Systolic Heart Failure
428.31 Acute Diastolic Heart Failure
428.33 Acute on Chronic Diastolic Heart Failure
428.41 Acute Systolic & Diastolic Heart Failure
428.43 Acute on Chronic Systolic Heart Failure
428.0
Congestive Heart Failure Not Otherwise Specified
428.9
Heart Failure Not Otherwise Specified
Major Small & Large Bowel Procedures
$14,732(1.8415)
$23,148(2.8935)
$36,047(4.5059)
Payment
Payment Weight
MS-DRG 331 MS-DRG 329MS-DRG 330
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Some conditions that are no longer CCs
CHF Chronic blood loss
anemia Dehydration COPD
Chronic Renal Failure Stage I-III
Seizure Disorder Angina (stable) Atrial Fibrillation Hyperkalemia
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UTI vs. Septicemia Example
CMS DRG 320 MS-DRG 688 MS-DRG 871PDx: Urosepsis PDx: Urosepsis PDx: SepticemiaSDx: Dehydration SDx: Dehydration SDx: Dehydration COPD COPD COPD
UTI Malnutrition
Decubitus Hip Shock
RW .8769 RW .7018 RW 1.8632$4,278 $3,423 $9,089
APR DRG 463 No change APR DRG 720SOI Subclass 2 SOI Subclass 4RW .5973 RW 3.3739ROM Subclass 2 ROM Subclass 4Peer Mortality: .8% Peer Mortality: 42.4%
DRGWith CC
No longer CCs
Major CC, but only if
site specified
In current CMS system, Septicemia
was reimbursed at
$7,803
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The Challenge
Physician Documentation is recorded in
CLINICAL terms
Documentation for coding, profiling & compliance must contain specific
DIAGNOSTIC terms
Breakdown between the two
languages
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Common Documentation Issues
Unable to Code Acceptable to Code
LUL Infiltrate LUL Pneumonia
Hgb 5.2; Transfused Acute or Chronic Blood Loss Anemia
Emaciated; Total Protein/Albumin Low; Nutrition Supplements Started Malnutrition
ABG 7.22/68/44; Will Treat Accordingly Respiratory Failure, Acidosis, Alkalosis, Etc.
Will Rehydrate Patient Dehydration
BP 70/40 on Dopamine for Support Shock
Cardiac Enzymes Elevated; EKG Positive Acute MI
No Overt CHF; Will Continue Lasix and Lanoxin Compensated CHF
Unable to Void; Cathed for 600 cc Urinary Retention
Sputum Gram Stain with Large Amount Gram-Negative Rods; Will Cover with Rocephin Questionable Gram-Negative Pneumonia
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Gender: Female Age: 55Disposition: Died LOS: 11 Days
Principal Diagnosis: 431 Intracerebral hemorrhage
Case 1 Case2LOS
Case 3 Case 4 Description
Secondary Diagnoses
7872942731
78729427312867
787294273128675070
787294273128675070
78001
Other dysphagia Atrial fibrillationAcquired coagulation factor defPneumonitis due to inhalation of food or vomitus (MCC)Coma
MS-DRG 66 w/o CC/MCC 65 w/CC 64 w/MCC 64 w/MCC Intracranial hemorrhage or cerebral infarction
Reimbursement $5,025 $5,805 $7,546 $7,546
APR SOI 2 2 3 4
APR ROM 2 2 3 4
Expected Mortality Rate
14% 14% 39% 76%
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Questions