The policies that CMS publishes each year in the OPPS proposed rule don't always come as a surprise. Sometimes, CMS will announce its future intent in a previous rule in order to notify providers about data it is looking at or requesting comments on.
With quarterly code updates and other regulatory changes from CMS throughout the year, the chargemaster coordinator has to constantly monitor the healthcare landscape, but the final few months of the year remain the most challenging.
Modifier -25 (significant, separately identifiable E/M service by the same physician on the day of a procedure) is used to distinguish visits from procedures on the same day. It is not used to distinguish observation from a visit service on the same day.
Hospital outpatient therapeutic services, such as ED or clinic visits, that are paid under the OPPS or to critical access hospitals (CAH) on a cost basis must be furnished "incident to" a physician's service to be covered.