CMS wants your thoughts on its 2018 OPPS proposed changes. In various places in the proposed rule, CMS specifically asks providers to comment on the proposals. You may submit comments to the agency until September 11, 2017.
You may find significant changes to E/M reporting in the near future, including a pivot away from two key elements — history and physical exam — that largely determine a given level of service for your most common patient encounters.
It’s that time of year again – when HIM directors, hospital administrators, and coding managers begin to wonder just how they will be affected come October 1.
The 2018 OPPS proposed rule includes potential changes to 340B drug discount payments, the inpatient-only list, packaging for low-level drug administration services, and more.
Rose T. Dunn, MBA, RHIA, CPA, FACHE, FHFMA, CHPS , explains that as a coding manager, whether your inpatient team is on-site, off-site, or remote, creating the appropriate environment and selecting proper locations are key to any successful team. Note: To access this free article, make sure you first register here if you do not have a paid subscription.
In late June, CMS released a major proposed rule that hospitals will need to pay attention to—and no, I don’t mean to say that CMS released the CY 2018 OPPS proposed rule early, though we’ve thought that might happen since it’s been at the Office of Management and Budget (OMB) for several months.
As CMS and third-party payers have looked for ways to treat patients in the outpatient setting and reduce inpatient volumes, CMS has used the 2-midnight rule, in addition to other methods, to treat patients as outpatients or in observation whenever possible.
Every now and then, the HCPro Boot Camp instructors are asked similar questions on a specific billing issue from students and clients across the country. The old saying “there must be something in the water” often holds true, and it does in this case, especially regarding recent OIG audits.
In today’s virtual environment, with its focus on flexible schedules, organizing an inpatient coding team requires consideration of time zones, team member skills, volume of work, and claim-processing schedules. Note: To access this free article, make sure you first register here if you do not have a paid subscription.
There is an extensive list of coverage requirements that must be met to furnish outpatient services to Medicare beneficiaries. Gina M. Reese, RN, JD, CPHRM , discusses some of the trickier issues that facilities will need to audit more carefully while monitoring for compliance in provider-based departments.
The Ochsner Health System in Louisiana revolutionized the way its clinical documentation excellence (CDE) team captures annual hierarchical condition categories for all patients across its vast system. Now, Ochsner can serve as a case study to educate others on how to create an outpatient focus on CDI in an increasingly risk-adjusted world.
When CMS introduced Hierarchical Condition Categories with risk-adjusted scores, Ochsner Health System began efforts to educate providers and improve documentation across its many facilities.
There is an extensive list of coverage requirements that must be met to furnish outpatient services to Medicare beneficiaries. Hospitals may find that certain coverage requirements for therapeutic and diagnostic service are more difficult to meet than others, especially in off-campus provider-based departments.
Coding plays a large role in claims and therefore is a key factor in reimbursement compliance. As such, coders have a responsibility to be as accurate and up-to-date on coding practices as possible. Rose T. Dunn, MBA, RHIA, CPA, FACHE, FHFMA, CHPS , explores some of the organizations and regulatory bodies available to assist coders.
Traditionally, the OPPS rulemaking cycle has been the main vehicle for changes to outpatient coding and billing regulations and policy that hospitals need to pay attention to. But increasingly, CMS has been introducing or discussing changes relevant to outpatient hospitals beyond the scope of the OPPS rules.
HCCs are the basis for risk adjustments for reimbursement models like Medicare Advantage, accountable care organizations, and other value-based purchasing measures such as Medicare Spending Per Beneficiary. Poor understanding and application of HCCs mean that a hospital’s patients may be much sicker in reality than they appear to be on paper, and that will hit reimbursement hard.
Accurate clinical documentation is the bedrock of the legal medical record, billing, and coding. It is also the most complex and vulnerable part of revenue cycle because independent providers must document according to intricate and sometimes vague rules.
Medicare recently published revisions to its appeals process, focusing on the Administrative Law Judge (ALJ) level of appeal. These revisions were published in the Federal Register in the form of final regulations on January 17, 2017, and became effective March 20.
The 2017 calendar year marks the beginning of a new approach to physician payment through the Quality Payment Program (QPP), an initiative created by the Medicare Access and CHIP Reauthorization Act to revise the physician payment system previously updated through the Sustainable Growth Rate.
The intersection of CMS’ packaged payment policy and the increasing volume of Medically Unlikely Edits (MUE) can be likened to a car crash waiting to happen. Hospitals are having valid, medically necessary claim lines denied – including charges and units below MUE limits. Providers can help stop the crash by ensuring their claims, CPT coding, medical necessity, and the units are all correct.
Accurate clinical documentation is the bedrock of the legal medical record, billing, and coding. It is also the most complex and vulnerable part of revenue cycle because independent providers must document according to intricate and sometimes vague rules.
As OPPS packaging has increased, providers may be less likely to appeal claims for certain denied charges based on medically unlikely edits, since it would not increase payments. However, providers should consider appeals when services are medically necessary and appropriate, as CMS bases future payment rates on accepted claims.
With a new year underway, providers likely need to get a handle on some key new modifiers, as well as important changes to an existing modifier and the deletion of a modifier that previously raised a lot of questions and operational concerns.
The focus for clinical documentation improvement (CDI) specialists has historically been on the inpatient hospital stay. Review of the chart for conditions that are not fully documented and/or evidence of conditions not documented at all has been standard practice.
With a new year underway, providers likely need to get a handle on some key new modifiers, as well as important changes to an existing modifier and the deletion of a modifier that previously raised a lot of questions and operational concerns.
Coding managers cannot always monitor every guideline update or coding-related issue targeted by the Office of Inspector General. Rose T. Dunn, MBA, RHIA, CPA, FACHE, FHFMA, CHPS, reviews what a coding manager can do during a coding audit and how to implement a plan.
Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC, CDIP, writes about the challenges faced in OB hospitalist practices and which procedures and services to focus on for coding, billing, and documentation.
Managers should not assume that they can review every guideline, every item in Coding Clinic , or every coding-related issue targeted by the Office of Inspector General (OIG) or Recovery Audit Contractor (RAC).
The 2017 OPPS final rule brings the end of modifier –L1 for separately reportable laboratory tests, along with changes to CMS’ packaging logic. Jugna Shah, MPH, and Valerie A. Rinkle, MPA, review how these changes will impact providers.
Chronic care management codes were adopted by CMS in 2015, but relatively few providers use them. Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC, CDIP, writes about the criteria needed to code and bill these services, as well as how coders can work with providers to ensure documentation supports the codes.
Each year, CMS reviews procedures on the inpatient-only list, which consists of services typically provided on inpatients and not payable under the OPPS, to consider whether they are being performed safely and consistently in outpatient departments.
As it does each year, CMS reviewed its packaging policies and proposed numerous modifications for 2017, finalizing a move to conditionally package at the claim level and deleting the controversial modifier used to identify separately reportable laboratory tests.
CMS made certain concessions from its proposed site-neutral payment policies required by Section 603 of the Bipartisan Budget Act, but it is still moving forward with implementation January 1, 2017, according to the 2017 OPPS final rule.
Rose T. Dunn, MBA, RHIA, CPA, FACHE, FHFMA, CHPS, writes about methods coders can use to improve the quality and detail of physician documentation to ensure important information is captured.
Providers need to make sure that electronic order templates include all the necessary information to bill correctly and avoid issues during audits. Valerie A. Rinkle, MPA, writes about what must be contained in the order and ICD-10-specific updates providers should consider.
Orders for services are a vital component of ensuring Medicare coverage. With the advent of computerized provider order entry (CPOE), it is important to review order templates in the electronic medical record (EMR) and the resulting order produced or printed in the formal legal medical record to ensure the templates meet requirements.
With only 60 days between the OPPS final rule's release and the January 1 implementation date, providers will be ahead of the curve by spending time now and thinking about the processes they may need to review, change, or implement based on what CMS finalizes and the sort of financial impact the final rule is likely to have.
Facilities may not yet be using clinical documentation improvement staff to review outpatient records, but the increasing number of value-based payment models and Medicare Advantage patients could make the practice worthwhile, according to Angela Carmichael, MBA, RHIA, CDIP, CCS, CCS-P, CRC, and Lena Lizberg, BSN.
The 2017 OPPS final rule is scheduled to be released in just a few weeks. Jugna Shah, MPH, writes about what facilities should be preparing for in case some of CMS’ proposals related to off-campus, provider-based departments, packaging, and device-intensive procedures are finalized.
The Medicare Reporting and Returning of Self-Identified Overpayments final rule (81 Fed. Reg. 7654‑7684), which became effective March 14, is designed to implement Section 1128J(d) of the Social Security Act, which was established under Section 6402(a) of the Affordable Care Act, effective March 23, 2010.
Billing correctly for observation hours is a challenge for many organizations. Getting it right requires knowing how to calculate observation hours for each patient, which is far from straightforward. Janet L. Blondo, LCSW-C, MSW, CMAC, ACM, CCM, C-ASWCM, ACSW, writes about how to properly calculate hours and report observation services properly.
Coders may not be aware of the impact place of service codes can have on coding and billing. Lori-Lynne A. Webb, CPC, CCS-P, CCP, CHDA, COBGC, CDIP, writes about how the codes are used and what coders should know about their application.
CMS’ proposed changes to implement Section 603 of the Bipartisan Budget Act of 2015 would reshape payments for off-campus, provider-based departments (PBD) if finalized and represent the most significant changes in the calendar year (CY) 2017 OPPS proposed rule.
CMS proposes aligning its conditional packaging logic with how it applies packaging to labs, while also proposing to delete the much-maligned modifier -L1 for separately payable laboratory tests in 2017.
CMS released the 2017 OPPS proposed rule on July 5 without much fanfare. On July 14, the Federal Register version was posted, and upon initial review, it seems rather short at 186 pages.
Jugna Shah, MPH, and Valerie Rinkle, MPA, recap CMS’ proposed changes to packaging logic in the 2017 OPPS proposed rule, as well as plans for new and deleted modifiers.
