DeGerome, James

The Digestive Disease National Coalition (DDNC) is an advocacy organization comprised of 28 voluntary health organizations and professional societies concerned with the many diseases of the digestive tract. Since its founding in 1978, the coalition has worked to increase public awareness on digestive illnesses such as inflammatory bowel disease, liver disease, colorectal cancer, irritable bowel syndrome, pancreatic disease among others. We have learned that in the Medicare Proposed Inpatient Hospital Rule that CMS is proposing to add gastroparesis code 536.3 to the "unacceptable principal diagnosis" edit in the Medicare Code Editor. The DDNC opposes adding gastroparesis, code 536.3, to the list of unacceptable principal diagnosis in the Medicare Code Editor. The DDNC understands that a note in the ICD-9-CM manual for 536.3 directs users to sequence the code of the underlying disease first. However, this note and the proposed code edit based on it may have resulted in a misunderstanding about the clinical nature of gastroparesis. Gastroparesis is an increasingly recognized disorder, one that is hard to treat, and one that patients may need hospitalization for exacerbation of their symptoms (nausea, vomiting, abdominal pain) and for treatment of their symptoms. Gastroparesis is frequently due to diabetes or other underlying disorders. However, in about one-third of cases of gastroparesis, no underlying diagnosis is identified, for which the condition is termed idiopathic gastroparesis. For diabetic gastroparesis, the underlying disorder for 536.3 is diabetes. However, for the many patients with idiopathic gastroparesis, there is no underlying disorder for their 536.3 code. Thus, there will be confusion for the many patients with idiopathic diagnosis – there will be no billable code for these patients. Allowing code 536.3 to continue to be assigned and submitted as the principal diagnosis is necessary to describe these cases of idiopathic gastroparesis. Rather than changing the edit, we suggest the faulty note in the ICD-9-CM manual be corrected instead. The DDNC would like to thank CMS for its work on diagnosis codes and gastroparesis diagnosis. The DDNC will provide more information concerning gastroparesis diagnosis through its membership.