2021 Medicare Inpatient Only Lists

As a benefit to members, the American College of Physician Advisors (ACPA) provides updated Medicare Inpatient Only Lists by Specialty each year and 2021 is no different. These documents are set up in the same manner as in previous years, with “Inpatient Only” procedures and their CPT/HCPCS codes listed on the left side of the page and “Not Inpatient Only” procedures with their CPT/HCPCS codes listed on the right side. This design gives users a more thorough view of the codeset than currently exists, so nuances can be readily identified which may swing a procedure between an inpatient (IP) only procedure or not.

In previous years, we highlighted changes to the list in yellow (both new procedures and procedures that changed between IP only and not IP only). This year, the Centers for Medicare and Medicaid Services (CMS) drew a distinction between procedures removed from the IP only lists prior to January 1, 2021, and those removed on or after that date. Procedures removed on or after January 1 qualify for exemption from status denials for what is currently an indefinite period of time until the procedure is more commonly done in the outpatient setting than the inpatient setting over a whole year. While CMS reserved the right to modify the exemption period in the future, it is likely that procedures removed from the IP only lists on Jan 1, 2021 and thereafter will generally have a longer exemption period than the 2-year exemption period that was granted to procedures removed from the IP only list prior to Jan 1, 2021.

As such, it is now important to distinguish procedures which qualify for this indefinite exemption. This year, we have used green shading throughout the lists to identify these procedures which are currently covered by the indefinite exemption. In contrast, the yellow shading will represent only new CPT/HCPCS procedure codes added to either the IP only or not IP only lists (or an existing procedure that changes from not IP only to IP only – there were none this year). The yellow shaded procedures do not have the indefinite exemption from status review – they merely represent new codes for CY 2021 or mid-year CY 2020.

CMS intended to remove all musculoskeletal procedures from the IP only for CY 2021. You will find that the specialty lists with the most changes include lists for Oral and Maxillofacial Surgery, Ortho Upper and Lower Extremity, and Spine. However, the changes were not limited to these lists, or even musculoskeletal procedures in general. In addition, musculoskeletal spine procedures that exist in the 6xxxx CPT codesets – which tend to be decompressive surgeries – were not removed from the IP only list for CY 2021.

CMS intends to fully abolish the IP only list over three years, so this year is just the first of the changes. Our current plan is to follow a similar approach for the CY 2022 IP only list. When the list is fully abolished in CY 2023, the only list that may be necessary is one which contains procedures which remain on the review exemption list.

We’d also like to emphasize that the official IP only list remains CMS OPPS Addendum E. In addition, the CPT codeset is owned and maintained by the American Medical Association (AMA), which does revise code descriptions from time to time. The HCPCS codes are maintained by CMS. These organizations remain the “sources of truth” in this space, and ACPA’s lists cannot be solely relied upon to be definitive in differentiating IP only from not IP only procedures.