Help Get Delirium Reclassified

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Help Get Delirium Reclassified

YOUR support is needed by June 10
Advocacy to the Centers for Medicare and Medicaid Services (CMS) aimed at reclassifying delirium as a major complication or comorbidity (MCC) needs your immediate support.

The ACLP, along with 10 other organizations (Figure 1), supported a request to CMS that delirium achieve parity with acute encephalopathy. The detailed rationale for this request is available online.

According to Mark Oldham, MD, FACLP, co-chair of the ACLP Proactive C-L Psychiatry SIG and co-author of the Academy’s original submission: “Obviously, delirium implies the presence of an acute encephalopathy. Delirium, with its clear clinical definition and extensive supporting literature, should not be designated as a lower complexity.”

A proposed rule, FY 2025 IPPS/LTCH PPS, has just been published online for public comment. It recommends against reclassifying delirium (see pp 172-176).

Further, delirium warrants reclassification because it satisfies CMS’s nine guiding principles for re-evaluating MS-DRG severity levels:

Since 2007, the ICD diagnostic codes for acute encephalopathy have been classified as greater severity than delirium in the Medicare Severity Diagnosis Related Group (MS-DRG) system. This means they are reimbursed at a lower rate and have less of an impact on hospital metrics.

As a result, US clinicians have preferentially coded toxic or metabolic encephalopathy instead of delirium because of the compelling financial incentive.

In an urgent call to action, ACLP’s Board has asked all Academy members to comment on the proposed rule before the June 10 deadline.

YOUR Comment Can Make A Difference

  • Visit and let CMS know that you support designating causally specified delirium as MCC, with no disparity between acute encephalopathy and delirium.
    • Click ‘comment,’ enter your opinion, and under ‘What is your comment about?’ click ‘Physician – HC005.’
    • In your comments, please refer to file code ‘CMS-1808-P.’
    • Additional details about eligible responses are included in the proposed rule.
  • If you wish to expand your comments, describe how delirium addresses all nine of CMS’s guiding principles for severity level designations.
  • The published rationale provides further discussion you can include in your comments.
  • Invite all your colleagues across specialties to contact CMS.
  • Invite your other medical organizations to do the same.


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