2020 Proposed Rule Changes For ICD-10-CM Codes

2020 Proposed Rule Changes For ICD-10-CM Codes

Tune in to this monthly online coding column, facilitated by AHIMA’s coding experts, to learn about challenging areas and documentation opportunities for ICD-10-CM/PCS.

By Natalie Sartori, M.Ed., RHIA


The Proposed Inpatient Prospective Payment System (IPPS) Rule was published on April 23, 2019. The ICD-10-CM code changes contained in the FY 2020 Proposed Rule Tables revealed 273 new codes, 21 deleted codes, and 30 code title revisions. The rule also proposes nearly 1,500 changes to complication or comorbidity/major complication or comorbidity (CC/MMC) designation and most of the severity changes are downgrades. The number of new codes by chapter can be viewed in Table 1 below.

New Codes

Table 1

Chapter # Chapter Title New Codes
3 Diseases of the blood and blood-forming organs and certain disorders involving the immune mechanism (D50-D89) 5
8 Diseases of the ear and mastoid process (H60-H95) 1
9 Diseases of the circulatory system (I00-I99) 30
12 Diseases of the skin and subcutaneous tissue (L00-L99) 25
14 Diseases of the genitourinary system (N00-N99) 3
17 Congenital malformations, deformations and chromosomal abnormalities (Q00-Q99) 31
18 Symptoms, signs and abnormal clinical and laboratory findings, not elsewhere classified (R00-R99) 3
19 Injury, poisoning and certain other consequences of external causes (S00-T88) 87
20 External causes of morbidity (V00-Y99) 75
21 Factors influencing health status and contact with health services (Z00-Z99) 13
                                                                                     TOTAL 273


Significant changes for some of the chapters are highlighted below.

Chapter 9: Diseases of the circulatory system (I00-I99)

There are four new atrial fibrillation codes and two existing codes (I48.1, I48.2) have been deleted. The new codes are:

  • 11, Longstanding persistent atrial fibrillation
  • 19, Other persistent atrial fibrillation
  • 20, Chronic atrial fibrillation, unspecified
  • 21, Permanent atrial fibrillation

There are eight new codes added to subcategory I80.2, Phlebitis and thrombophlebitis of other and unspecified deep vessels of lower extremities, to identify phlebitis and thrombophlebitis of the peroneal vein and calf muscle veins. Specific codes for these lower extremity veins have also been added to subcategories:

  • 4-, Acute embolism and thrombosis of deep veins of lower extremity
  • 5-, Chronic embolism and thrombosis of deep veins of lower extremity

Chapter 12: Diseases of the skin and subcutaneous tissue (L00-L99)

Category L89, Pressure ulcer, has been expanded with a sixth character of “6” which indicates pressure-induced deep tissue damage of various anatomic sites. Currently, deep tissue injuries code to “pressure ulcer unstageable,” but there can be significant clinical differences between unstageable ulcers and deep tissue injuries. Unstageable ulcers occur when eschar obscures the ability to stage the ulcer, but once removed a stage 3 or 4 ulcer is typically revealed. Deep tissue injuries often have dual etiology that include pressure and ischemia and do not always result in tissue loss. These new codes will have a severity status of Complication/Comorbidity (CC).

Chapter 17: Congenital malformations, deformations and chromosomal abnormalities (Q00-Q99)

Several codes have been added to category Q66, Congenital deformities of feet, to provide specificity for laterality. Subcategory Q79.6, Ehlers-Danlos syndrome (EDS) has added a fifth character to specify the most common and severe types of EDS.

Chapter 19: Injury, poisoning and certain other consequences of external causes (S00-T88)

Several new subcategories have been added to specify fractures of the orbital roof and individual orbital walls frequently seen in facial trauma cases. Poisoning codes have been added for poisoning by multiple medicaments (T50.91-) and heatstroke/sunstroke (T67.0-).

Chapter 20: External causes of morbidity (V00-Y99)

Currently ICD-10-CM category Y35, Legal intervention, does not completely capture mechanisms of injury in encounters between civilians and law enforcement. Codes have been added to when the injured person is not specified as either law enforcement, bystander, or suspect. Some legal intervention codes fail to provide the necessary specificity to track for public information, law enforcement, and morbidity and mortality data collection and reporting purposes. Subcategory Y35.8, Legal intervention involving other specified means, has been expanded to capture injuries caused by conducted energy devices (CED) such as TASER devices.

Severity Changes

Along with the ICD-10 updates, the proposed rule includes nearly 1,500 CC/MCC designation changes for ICD-10-CM codes. Most of the changes (87.2 percent) involve a reduction in the severity level, but there are a handful of codes (12.8 percent) where the severity level increased. Table 2 below provides an overview number of codes for each category of designation change from Table 6p.1c.

Table 2

Current Severity Level Proposed FY 2020 Level Number ICD-10-CM Codes Percent of Total
Non CC CC 183 12.3%
CC MCC 8 0.5%
CC Non CC 1149 77%
MCC CC 136 9.1%
MCC Non CC/MCC 17 1.1%


Some common examples by severity class change are listed below to provide an overview and some insight into the detail of specific codes changes.

Severity Level Increases

Non-CC To CC:

  • Heparin-induced thrombocytopenia (HIT)
  • Stage 1 and 2, unstageable and unspecified pressure ulcers
  • Foreign bodies in respiratory tract with asphyxiation
  • Acute bronchospasm
  • Homelessness
  • Neutropenia and agranulocytosis
  • Epistaxis and throat hemorrhage


  • Bacteremia
  • Candidal esophagitis and enteritis
  • Moderate protein calorie malnutrition
  • Severe persistent asthma with exacerbation

Severity Level Decreases


  • Sickle Cell disease with crisis/complication
  • Cardiac arrest
  • Complicated acute appendicitis

MCC to CC:

  • STEMIs – initial and subsequent
  • Unspecified severe protein-calorie malnutrition
  • Ventricular fibrillation/flutter
  • Stage 3 and 4 pressure ulcers
  • Femur fractures
  • Postoperative acute respiratory failure

CC to Non-CC

  • GI, respiratory, pancreatic central and peripheral nervous system, GU, connective and skeletal system primary and secondary neoplasms
  • Kaposi’s sarcoma
  • Leukemia and lymphomas
  • Acute blood loss anemia
  • Chronic heart failure
  • Ulcerative colitis and Crohn’s disease
  • Cutaneous abscess
  • Reiter’s disease
  • Stage 4 and 5 CKD
  • BMI 19.9 or less
  • BMIs 40.0 – 44.9 and 45.0 – 49.9
  • Transplant status

The tables 6A-6K and tables 6P.1c-6P.1e with ICD-10 code changes and severity level changes are available online and can viewed on the Centers for Medicare and Medicaid Services’ FY 2020 IPPS Proposed Rule Home Page:



Natalie Sartori (natalie.sartori@uasisolutions.com) is corporate trainer at United Audit System Inc.

Leave a comment


  1. Chronic is afib due to another condition, longstanding is longer than 12 months, persistent is more than 48 hours but less than 12 months, permanent indefinite and no longer responds to treatment.

  2. Please provide definitions for atrial fibrillation types

  3. Great article. Question on A-fib changes. What is the difference between persistent, longstanding, chronic, and permanent a-fib? Do you have clear definitions of the progression of each of these words? When does persistent become longstanding? When does longstanding become chronic? When does chronic become permanent?

  4. The MCC to CC list does not seem acceptable in that those dx require a lot of resources to manage and facilities should be compensated accordingly. Please reconsider these changes based on severity of the patient.

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