Tuesday, April 19, 2022

Brief Blog: CMS Releases Annual Inpatient Propose Rule (FY2023)

As usual for 2H April, CMS releases the proposed inpatient rulemaking for the upcoming fiscal year.

  • Find the press release here.
  • Find the detailed Fact Sheet here.
  • Find the home page for the rule here.
  • Find the pre-publication (typescript) PDF here.  1768pp.
    • Typeset rule in Federal Register, May 10.
    • Comments to June 17.
See a quick ten-point summary at Becker's, here.

Last year, there was quite a bit of policymaking around what level of detail to require in ICD-10 codes.  At the same time (Spring 2021) that CMS was proposing reasonable changes for DRG coding, CMS had proposed just-plain-crazy changes to coding for the Next Gen Sequencing NCD, 90.2 (story here).


Find the always-interesting sections for add-on payments for new technologies, beginning at typescript page 247 and running to page 629.  It looks like there are 13 products ("a" through "m").  (Fun fact - they are discussed in alphabetical order.)  There's a discussion of "alternative" NTAP pathways at page 547, whether to post applications (p. 623), whether to use NDC codes to identify NTAP drugs (p. 616).  

Several recent-past NTAP products have used artificial intelligence (e.g. screening CT images for pulmonary embolisms or strokes).   Some have won NTAP payment, interesting since a radiology AI system for bone mass and fractures is classified as unpayable in the hospital outpatient system (see CMS OPPS rule for code 0691T).   

This year, the NELLI Seizure Monitoring system is discussed "to enable detection of epileptic events using pretrained artificial intelligence." (P. 585.)  

Also, the TAVI Coronary Obstruction Module (p. 592) using "intelligent decision support powered by AI and machine learning."  Those look like the only two machines of AI or ML in this year's rule.


For those who track debates around the sepsis measure SEP-1 (0500) it's in the rule in its usual place among quality measures, and scheduled to stay there through at least FY2028 (p. 1207). It's one of only two laboriously chart-abstracted measures, along with "elective delivery" (0469) which requires manual abstraction but is quite rare among Medicare patients.