Top 5 Highlights FY 2020 Coding Changes

Cathie Wilde, RHIA, CCS - Director, Coding Services Education 1 Comment

Top 5 Highlights FY 2020 Coding Changes

The FY 2020 IPPS final rule was released by the Centers for Medicare and Medicaid (CMS) on August 2, 2019.[1] Below are five highlights to be aware of regarding changes to ICD-10-CM, ICD-10-PCS, and corresponding official guidelines in FY 2020.


  1. Effective October 1, 2019 there are 273 new ICD-10-CM codes, 21 deleted ICD-10-CM codes and 30 ICD-10-CM code title revisions.  
  2. In the proposed rule, close to 1,500 changes to the complication/comorbidity (CC/MCC) designations were proposed with the majority resulting in a downgrade. However, largely due to the comments received during the comment period, these proposed revisions will be postponed for review and implementation in FY 2021 and perhaps with a phased-in approach. The final CC/MCC changes for 2020 are minimal comparably to the proposed and include adding chronic atrial fibrillation (I48.2-) and drug resistance codes (Z16.1- to Z16.3-) to the CC list.
  3. New codes include codes for glucose-6-phosphate dehydrogenase deficiency without anemia (D75.A), subsegmental pulmonary embolism (I26.93, I26.94), new codes in category 182 (other venous embolism and thrombosis) to identify specific vessels in lower extremity, pressure-induced deep tissue damage (L89.—6) and additions/revisions in Chapter 21, Factors Influencing Health Status.
  4. Code expansions include fifth digit code expansions for subcategory D81.3- (adenosine deaminase deficiency), persistent atrial fibrillation (I48.1-), chronic atrial fibrillation (I48.2-), added specificity for Ehlers-Danlos syndrome (Q79.6-) and revisions to heat stroke (T67.0-) to identify different types.
  5. There are hundreds of revisions to the tabular instructions including change in excludes notes for reporting eating disorders of nonorganic origin (F50.-) and malnutrition (E40-E46) with codes from the symptoms and signs concerning food and fluid intakes (R63.-)

ICD-10-CM Official Guidelines for Coding and Reporting[3]

  1. Revision to guideline I.C.9.e.5. clarifies that the underlying cause of a Type 2 myocardial infarction is coded first.
  2. New guideline that clarifies injuries from Chapter 19 should not be assigned for injuries that occur during, or as a result of, medical intervention (i.e. iatrogenic injuries) but rather assign to appropriate complication code(s) (guideline I.C.19.b.3.). Guideline I.C.19.g.5. elaborates that complication codes from the body system chapters should be assigned for intraoperative and postprocedural complications unless the complication is specifically indexed to a T code in Chapter 19.
  3. Guideline I.C.19. e.4. has new terminology stating if multiple unspecified drugs, medicinal or biological substances were taken, assign the appropriate code from subcategory T50.91, Poisoning by, adverse effect of and underdosing of multiple unspecified drugs, medicaments, and biological substances.
  4. New guideline (I.C.12.a.7.) stating for pressure induced deep tissue damage or deep tissue pressure injury, assign only the appropriate code for pressure-induced deep tissue damage (L89.--6).
  5. The phrases “compatible with” and “consistent with” have been added to the terminology of uncertain diagnosis under guidelines II.H., III.C. and IV.H


  1. For FY 2020 ICD-10-PCS there are 734 new codes, two code revisions and 2,056 deleted coded. Changes in PCS for FY 2020 include additions of new qualifiers (e.g. qualifier “Y” hyperthermic for peritoneal cavity body system in Table 3E0), approaches (e.g. approach character 4, percutaneous endoscopic in Table 3E1), body parts (e.g. new row added in Table 0WC for upper and lower jaw body parts), device characters (e.g. new device character F, subcutaneous defibrillator lead added to tables 0JH, 0JP and 0JW) and new tables (e.g. X27, Dilation, Cardiovascular System with new intraluminal device, sustained release drug-eluting device for lower extremity arteries).
  2. Deletion of the qualifier value “bifurcation” from the peripheral artery body systems, upper and lower arteries. The bifurcation qualifier was originally intended only for procedures on the coronary arteries (Heart and Great Vessel Body System).
  3. Deletion of the approach value, X for “external” from the breast body part values in the Skin and Breast Body System in order to make a distinction between procedures on the breast and procedures on chest wall skin. Now, all procedures performed on the skin of the breast will be classified to the skin, chest  body part with external approach. The change impacts all tables in Skin and Breast tables except Change (2) and Reattachment (M)
  4. Table 0D1, Bypass GI System now has two new rows identifying body parts for small intestine (8) and large intestine (E) with qualifiers for cutaneous, small intestine, large intestine, cecum, ascending colon, descending colon, sigmoid colon, rectum and anus.
  5. The FY 2020 update brings the total number of ICD-10-PCS codes to 77,559 from 78,881 in 2019.

ICD-10-PCS Official Guidelines for Coding and Reporting[5]

  1. Paragraph 3 of the introduction has added in reference to the guidelines “They are intended to provide direction that is applicable in most circumstances. However, there may be unique circumstances where exceptions are applied”; no example of exceptions provided.
  2. The wording of the first sentence for guideline B3.1b. has been revised to state “Components of a procedure specified in the root operation definition or explanation as integral to that root operation are not coded separately”. An exception has been added referencing that for a mastectomy followed by breast reconstruction, both the resection and replacement are coded separately.
  3. Guideline B3.9 Excision for graft has been revised to include an exception stating that an autograft obtained from a different procedure site is coded as a separate procedure except when the seventh character qualifier value in the PCS table fully specifies the site from which the autograft was obtained. The example of replacement of breast with autologous deep inferior epigastric artery perforator (DIEP) flap has been added demonstrating the exception. In this case, the excision of the DIEP flap is not coded separately as the seventh character qualifier value of DIEP is included in the PCS table and fully specifies the site from which the autograft was obtained.
  4. New Radiation Therapy Section (D.) reviews the appropriate coding of brachytherapy with an example and exception as well as the coding of a temporary applicator for delivering the brachytherapy.
  5. The former D. New Technology Section has been moved to E. with a new guideline (E1.b) addressing the coding of multiple procedures.

This top five gives you a glimpse at the changes for coding teams to be absorbed and put into practice as we reach October 1, 2019.  It is time to ensure you have a training plan in place for your team.





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