The January quarterly I/OCE update includes new modifiers, changes related to expanded packaging, and continued refinement of CMS' skin substitutes categories, but the biggest change for outpatient hospitals is the implementation of comprehensive APCs (C-APC).
Editor's note: Andrea Clark-Rubinowitz, RHIA, CCS, CPCH , has more than 30 years of experience working with healthcare professionals, information systems, hospital coding, and operational and compliance training. She founded and led Healthcare Revenue Assurance Associates from 2001 to 2014. Contact her at 954-465-0968 or aclark5678@gmail.com .
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.
When an NCCI edit occurs on a claim, providers can go directly to CMS’ website and download the latest edits to pinpoint why the edit occurred and what codes may be conflicting.
The April quarterly I/OCE update from CMS did not defy convention?featuring the typically small number of updates following extensive changes in the previous quarter?but CMS did continue to clarify the logic for comprehensive APC (C-APC) payments.
In a concerted effort to move healthcare payments to a system of "quality over quantity," CMS finalized policies that greatly expanded packaging for outpatient providers in the 2015 OPPS final rule. It also introduced complexity adjustments with comprehensive APCs (C-APCs).
Documentation and billing for observation stays has come under increased scrutiny from the OIG, though many hospitals have struggled with changing regulations and frequently updated guidance.
One of the major changes to the 2013 CPT Manual is the replacement of the term "physician" with "physician or other qualified healthcare professional" (QHP) in a wide range of codes.
Providers were glad to see CMS' ruling (CMS-1455-R) released March 13 (published in the Federal Register on March 18), which allows full Part B payment for inpatient stays that had been denied as not reasonable and necessary. The ruling had very few details on how the process would work, but on March 22, CMS published Transmittal R1203OTN instructing contractors and providers on the details.
