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.
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.
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.
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.
Just like the lyrics to the popular Gap Band song say, "You dropped a bomb on me… I won't forget it," there are definitely some changes in the 2017 ICD-10-CM Official Guidelines for Coding and Reporting that some of us may wish the Cooperating Parties will forget were ever mentioned.
In the outpatient setting, we have a different set of rules to follow in regard to the ICD-10-CM Official Guidelines for Coding and Reporting compared to those that follow the guidelines for inpatient care. The ICD-10-CM guidelines for outpatient coding are used by hospitals and providers for coding and reporting hospital-based outpatient services and provider-based office visits.
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.
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.
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.
