The biggest impacts to clinical documentation integrity (CDI) professionals for the 2026 fiscal year (FY) will not be associated with updates to the ICD-10-CM code set or the Inpatient Prospective Payment System (IPPS).
The biggest impacts will have to do with impending policy changes to Medicare and Medicaid. In my last article, I discussed Medicaid and uninsured patient volumes. This week, I want to discuss another threat to hospital patient volume: changes in the Medicare Inpatient-Only List.
The proposed OPPS rule for 2026 states, “For CY 2026, we propose to phase out the IPO List over three years, beginning with the removal of 285 mostly musculoskeletal services for CY 2026. (p. 16).” Currently there are approximately 1,731 services on the IPO. The factors being used to determine which procedures should be removed from the IPO List include:
The proposed rule acknowledges that it will generally be less expensive to provide these services in the outpatient setting, compared to the inpatient setting. As CDI professionals, we know surgical MS-DRGs pay higher than medical MS-DRGs, and as operating margins continue to tighten, the loss of surgical volume could be problematic for many hospitals.