The AAMC Feb. 20 submitted a letter to the Centers for Medicare and Medicaid Services (CMS), requesting that CMS include a Request for Information in the upcoming Fiscal Year (FY) 2020 Inpatient Prospective Payment System (IPPS) proposed rule to solicit feedback on the Medicare Severity Diagnosis Related Group (MS-DRG) reassignment of percutaneous Extracorporeal Membrane Oxygenation (ECMO).
The reassignment, made through the FY 2019 final rule, significantly reduces the reimbursement for percutaneous ECMO. Patients who require treatment with ECMO are critically ill and, without treatment, will likely not survive. The cost and complexity of care provided to these critically ill patients is unrelated to the method of cannulation. Lastly, these patients often seek treatment in teaching hospitals, and reducing reimbursement for this life-saving treatment may require some hospitals to reconsider whether to continue to offer it.
In the FY 2019 IPPS proposed rule, CMS proposed to keep ECMO cases as assigned in the MS-DRG because CMS clinical advisors indicated that, until there is a way to specifically identify percutaneous ECMO in claims data, it would not be clear what proposal to make. Based on the FY 2019 IPPS proposed action, many organizations determined that it was unnecessary to submit public comment on this specific issue but would monitor CMS actions in future rulemaking. CMS then finalized changes to the MS-DRG reassignment for ECMO in the FY 2019 final rule without adequate opportunity for public comment. Therefore, the AAMC has asked CMS to include an opportunity for stakeholders to elaborate on their concerns about the changes to the ECMO MS-DRG reassignment in the FY 2020 IPPS proposed rule.