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.
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.
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.
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.
CMS issued SE1609 to clarify long-standing policy concerning external infusion pumps. Apparently, both freestanding physician offices and outpatient hospital departments were treating external pumps as an item of durable medical equipment, even when the physician or hospital department set up the pump on the patient, supplied the drug, and programmed the infusion rate and dose into the pump.
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.
