In a letter to CMS, the American Hospital Association, Federation of American Hospitals, and Association of American Medical Colleges cited two independent studies that underscore their concerns about CMS’ methodology for determining the effect changes in documentation and coding (i.e., documentation and coding adjustment [DCA]) have had on the Medicare patient case mix index (CMI).
According to The Moran Company study:
Based on our review of the methodology, examination of the logic, and our own analyses, our conclusion is that the CMS methodology does not adequately isolate documentation and coding from other factors when calculating changes in CMI. CMS’ methodology cannot distinguish among the different causes of a change in average patient severity.
According to the study conducted by City University of New York economics professor Partha Deb:
CMS’ assertion that case mix has declined in the recent past is inconsistent with our findings. Multiple data sets and different measurement tools indicate that the Medicare population is indeed getting sicker.
In their letter, the three parties strongly recommended that CMS change its methodology in the inpatient prospective payments system final rule, which is expected to be released this month, and reduce the proposed 2.9% payment cut to take into consideration what the organizations believe is a trend of increasing patient severity.
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