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A Closer Look at the New ICD-10-CM Codes for Wound Management in 2020

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October 2019 is an excellent time to review the ICD-10-CM codes that are associated with wound management. The Fiscal Year 2020 ICD-10-CM codes, which became effective on October 1, 2019, fit into 2 major categories: new codes and revised codes. To view the entire list of new and revised ICD-10-CM codes, refer to Tables 6A-F in the Acute Inpatient Prospective Payment System (IPPS) Final Rule at this link: .

The IPPS Final Rule was published on August 16, 2019. The ICD-10-CM code changes contained in the FY 2020 IPPS Final Rule tables revealed 273 new codes, 21 deleted codes, and 30 code description revisions. In addition, the IPPS Final Rule tables revealed nearly 1,500 changes to the assignment of ICD-10-CM codes to the 3 Diagnosis Related Groups (DRGs) severity levels. Most of the 2020 severity level changes reassigned ICD-10-CM codes from the MCC severity level to the CC severity level, which reduced the Medicare payment for those diagnosis codes. Reminder: In most cases, inpatient Diagnosis Related Groups (DRGs) are divided into three severity levels, which align with 3 levels of payment.

1. Major complication or comorbidity (MCC) = the highest level of severity and the highest Medicare payment
2. Complication or comorbidity (CC) = a moderate level of severity and a moderate level of payment
3. Non-complication or comorbidity (Non-CC) = the lowest level of severity and the lowest level of payment  

New 2020 ICD-10-CM Codes

New ICD-10-CM codes that may be pertinent to wound management are displayed in Table 1 in the PDF at the top of this article, which is divided into 3 sections of new codes: 1) phlebitis, thrombophlebitis, 2) pressure ulcers, and 3) personal history, conditions.

Note that Category L89, pressure ulcer, has been expanded with a sixth character of “6,” which indicates pressure-induced deep tissue damage of various anatomic sites. Prior to the 2020 ICD-10-CM release, deep tissue injuries were coded as “pressure ulcers, unstageable,” but there could be significant clinical differences between unstageable pressure ulcers and deep tissue injuries. Unstageable pressure ulcers occur when eschar obscures the ability to stage the ulcer. Once the eschar is removed, a stage 3 or 4 pressure ulcer is usually revealed. Deep tissue injuries often have dual etiologies, that can include pressure and ischemia, and do not always result in tissue loss. The new pressure ulcer codes add specificity and have a severity status of CC.

Revised 2020 ICD-10-CM Codes

Revised ICD-10-CM code descriptions for existing ICD-10-CM codes are included in Table 2 in the PDF at the top of this article. They include revised codes for occlusion and stenosis or vertebral and carotid arteries, as well as infarctions due to thrombosis, codes for specific sites. In addition, there are revised codes for non-pressure ulcers of other sites with and without necrosis. Codes were also revised for chronic osteomyelitis of the humerus. There is a revised code for body mass index of 50–59.9, and there are revised codes for Shiga toxin-producing Escherichia coli.

Changes to the CC and MCC Systems

There are significant additions and deletions to the CC listing, as well as the MCC listing. All medical professionals who are participating in the Medicare Quality Payment Program should be aware of these changes because the severity level changes may impact their personal Merit-based Incentive Payment System/Medicare Access and CHIP Reauthorization (MIPS/MACRA) performance statistics. For example: Stage 3 and 4 pressure ulcers have been added to the MCC list, and Stage 1 and 2 pressure ulcers have been added to the CC list. The MCC and CC lists also specify codes that have been removed from each list.

The severity change tables can be found at the same IPPS Final Rule link displayed in the first paragraph of this article.

• Table 6G.1     Secondary Diagnosis Order Additions to the CC Exclusions List
• Table 6G.2    Principal Diagnosis Order Additions to the CC Exclusions List
• Table 6H.1     Secondary Diagnosis Order Deletions to the CC Exclusions List
• Table 6H.2     Principal Diagnosis Order Deletions to the CC Exclusions List
• Table 6I.    Complete MCC List
• Table 6I.1     Additions to the MCC List
• Table 6I.2        Deletions to the MCC List
• Table 6J.    Complete CC List
• Table 6J.1          Additions to the CC List
• Table 6J.2          Deletions to the CC List
• Table 6K.    Complete List of CC Exclusions

Recommended Implementation Actions for New and Revised 2020 ICD-10-CM Codes

After reviewing the new and revised 2020 ICD-10-CM codes, wound management professionals should:

1. Review the new 2020 ICD-10-CM code changes with your clinical and revenue cycle staff.
2. Ensure that the new 2020 ICD-10-CM codes are added to your electronic billing systems and forms.
3. Review all pertinent Medicare National Coverage Determinations (NCDs) and Local Coverage Determinations (LCDs), (such as wound management, cellular and/or tissue-based products for skin wounds, hyperbaric oxygen therapy, electrical stimulation and electromagnetic therapy) that are updated due to the ICD-10-CM code changes. The Centers for Medicare and Medicaid Services have already updated the NCDs and most Medicare Administrative Contractors have updated their LCDs to reflect the 2020 new/revised ICD-10-CM codes.
4. Review the MCC and CC listings to see the most common codes for wound management. Select those that are common to your wound management practice and ensure that they are documented and coded correctly to ensure credit for these severity related conditions as they occur with your patients.  

Here’s to a great 2020! Stay tuned for the changes to the Hospital Outpatient Prospective Payment System and to the Medicare Physician Fee Schedule, which will be released at the beginning of November and will be implemented on January 1, 2020.

Donna Cartwright is senior director of health policy and reimbursement at Integra LifeSciences Corp., Plainsboro, NJ. She is approved as a certified trainer on ICD-10-CM by the American Health Information Management Association and she has been designated as a fellow of the American Health Information Management Association.

Donna J. Cartwright, MPA, RHIA, CCS, RAC, FAHIMA
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