The Centers for Medicare & Medicaid Services (CMS) has implemented changes in the Medicare Severity-Diagnosis Related Group (MS-DRG) assignments for extracorporeal membrane oxygenation (ECMO) procedures that will negatively impact reimbursement to hospitals. These modifications were made without any stakeholder input and may result in a decreased reimbursement of 40% to 80% for the affected services.
As of October 1, 2018, ECMO that requires central cannulation will still be reported under MS-DRG 003; however, peripheral veno-arterial (VA) and peripheral veno-venous (VV) cannulation for ECMO have been reassigned to MS-DRGs 207, 291, 296, and 870.
Reasoning Behind the Changes
In evaluating changes to the International Classification of Diseases, 10th Revision (ICD-10-PCS) codes, which separate ECMO into central and peripheral ECMO, CMS’s clinical advisors determined that because central ECMO is an invasive procedure requiring a sternotomy and direct cannulation carries significant risk for complications, the ICD-10-PCS code for central ECMO would remain classified as an OR (surgical) procedure in MS-DRG 003.
CMS designated the new peripheral VA and VV ICD-10-PCS codes as non-OR (medical) procedures based on the clinical advisors’ indication that because percutaneous ECMO does not require a sternotomy and can be performed in the intensive care unit or at the bedside, the associated risks are different than those for central ECMO. However, the new peripheral VA and VV ECMO ICD-10-PCS codes do not differentiate between open peripheral and percutaneous peripheral cannulation, and CMS did not address the risk associated with open peripheral VA and VV ECMO.
As a result, all peripheral VA and VV ECMO procedures have been assigned to non-OR MS-DRGs, thus opening them up to major changes in reimbursement.
The Society is working in coalition with several other medical specialty societies and the American Hospital Association to address this misclassification of procedures. It is unclear whether any changes can be made for FY 2019, but STS will continue its efforts and, if necessary, comment to CMS on MS-DRG assignments for FY 2020. In addition, the Society will propose that peripheral cannulation be divided into open and percutaneous subsets in the ECMO ICD-10-PCS codes.
|ICD-10-PCS Code||ICD-10-PCS Description||MS-DRG||MS-DRG Title|
|5A15223||Extracorporeal Membrane Oxygenation, Continuous||003||ECMO or Tracheostomy with Mechanical Ventilation >96 hours or Principal Diagnosis Except Face, Mouth and Neck with Major O.R.|
|New ICD-10-PCS Code||ICD-10-PCS Description||MS-DRG||MS-DRG Title|
|5A1522F||Extracorporeal Oxygenation, Membrane, Central||003||ECMO or Tracheostomy with Mechanical Ventilation >96 Hours or Principal Diagnosis Except Face, Mouth and Neck with Major O.R.|
|5A1522G||Extracorporeal Oxygenation, Membrane, Peripheral Veno-arterial||
|Respiratory System Diagnosis with Ventilator Support >96 Hours or Peripheral Extracorporeal Membrane Oxygenation (ECMO)
Heart Failure and Shock with MCC or Peripheral Extracorporeal Membrane Oxygenation (ECMO)
|5A1522H||Extracorporeal Oxygenation, Membrane, Peripheral Veno-venous||
|Cardiac Arrest, Unexplained with MCC or Peripheral Extracorporeal Membrane Oxygenation (ECMO)
Septicemia or Severe Sepsis with Mechanical Ventilation >96 Hours or Peripheral Extracorporeal Membrane Oxygenation (ECMO)