Recent Articles
Never Events—CMS issues surgical error NCDs and related guidance
In 2002, the National Quality Forum (NQF) published a list of 27 events identified as “serious, largely preventable and of concern to both the public and health care providers.” These events have become more popularly known as “never events”—events that should never occur in a well-run health care facility with appropriate quality controls. The updated list currently contains 28 adverse events, including the following surgical errors:
- Wrong surgical or other invasive procedure performed on a patient;
- Surgical or other invasive procedure performed on the wrong body part; and
- Surgical or other invasive procedure performed on the wrong patient.
Manual changes related to condition code 44
I’d like to turn my attention to the manual changes related to condition code 44, as promised. Overall, the changes were designed to incorporate discussion and FAQs that were previously published in MLN Matters Article SE0622. In this respect, the changes to the manual have very few surprises. Almost everything added came directly from SE0622 and nothing added was really anything new. With that said, however, I do think that hospital case managers and anyone involved in condition code 44 cases or billing for cases with changed status should review the changes carefully to be sure they are following all the guidance provided.
MedicareFind tip: Know when to use quotation marks for your FIND!
What’s the difference between physician supervision and “physician supervision”? It turns out, quite a bit.
Performing a find for physician supervision (without quotation marks) means MedicareFind will look for documents that have ‘physician’ and ’supervision’ in them–they could be right next together, as in “physician supervision,” or very far apart, as in “the physician must provide supervision of the…” Performing a find for “physician supervision,” on the other hand, means that MedicareFind will look for documents where the full phrase “physician supervision” appears–in these documents, you’ll find the words appearing right next to each other at least once.
Take a look at the results page for physician supervision without quotation marks and with quotation marks. Notice that, without quotation marks, you receive about 5,800 results; with quotation marks, you receive about 1,400 results. So not using quotation marks can be helpful if you’re looking for all the information you can possibly find that might have to do with physicians and supervision–it returns a broad swath of results. Using quotation marks can be helpful if you’re looking for more targeted information that has to do directly with physician supervision.
Know which sort of results page you’d like to see–targeted or broad–and employ quotation marks (or don’t) accordingly. Try a free trial to MedicareFind and start FINDing!
CMS replaces the term ’observation status’ with ’observation services’
In the July 2009 quarterly updates, CMS revised portions of both the Claims Processing Manual and Benefit Policy Manual related to observation. These changes were characterized as “editorial” in nature, removing certain terms CMS felt were confusing and revising some sections in accordance with that. Additionally, a new section entitled “Policy and Billing Instructions for Condition Code 44” was added to Chapter 1 of the Claims Processing Manual, along with other revisions to information on condition code 44.
New modifiers for outpatient never events; billing for hospital-acquired conditions
This week, CMS published the July Integrated Outpatient Code Editor (I/OCE). Although there were relatively few changes, CMS did introduce three new modifiers for use with the occurrence of three never events identified by the National Quality Forum (NQF) that were recently the subject of National Coverage Analyses by CMS. The new modifiers are: PA for surgical or invasive procedure on the wrong body part, PB for surgical or invasive procedure on the wrong patient, and PC for wrong surgery or invasive procedure on patient. The modifiers were added to the list of valid modifiers effective January 1, 2009.
Mass adjustment to post-acute transfer cases assigned to MS-DRG 956
On May 8, 2009, CMS released transmittal R492OTN. This transmittal instructed Part A contractors (Fiscal Intermediaries and Medicare Administrative Contractors [FIs/MACs]) to download the revised FY 2009 IPPS Pricer and to mass adjust claims that meet the following criteria:
- Have a discharge date on or after October 1, 2008;
- Were assigned to MS-DRG 956; and
- Were assigned a transfer Price Return Code of ‘10’.
MedicareFind tip: Selecting your local contractor
Local coverage determinations, or LCDs, are included in the MedicareFind database. Because these coverage policies apply locally, rather than nationally, you’ll be interested only in the LCDs from your organization’s local contractors.
Here’s how you can narrow down to a specific contractor.
After typing in your query and clicking “Find,” click on “Local Contractor.” This is a filter available on the left side of the results, underneath the “Source” section. Clicking this narrows your results down a bit, and it also exposes a menu of further options–allowing you to narrow your results by Contractor Type (e.g., Carrier, FI, Part B MAC, etc.). Click on one of these filters (your results narrow again) and this will expose a list of contractor names for you to click on (e.g., NHIC, Palmetto, etc.). Simply click on the contractor you’re interested in and your results will narrow down to reveal only documents from that particular contractor–letting you see only those LCDs that matter to your organization.
Try a free trial to MedicareFind, and start FINDing!
MedicareFind tip: How to remove filters from your results
Filters are one of the best features of the MedicareFind database tool–these allow you to narrow your results down quickly by Document Type, Source, or Year/Month to find the document you need without sorting through pages of results. But how can you remove those filters to get back to the broader results?
To remove a filter, simply click on it again. Clicking on an already-selected filter will remove it and show you the broader list of results.
Try a free trial to MedicareFind and start FINDing!
Clarification of reference (non-patient) laboratory testing
CMS released Transmittal 1729 to the Claims Processing Manual this week, implementing provisions of the Medicare Improvements for Patients and Providers Act (MIPPA) regarding payment of reference laboratory tests performed at a Critical Access Hospital (CAH). Although directed at CAHs, this is a good opportunity to review the rules for reference lab billing for OPPS hospitals as well. This is a common area of confusion for hospitals because of the definition of non-patient in the context of reference lab services. See Claims Processing Manual, Chapter 16, Section 40.3, as revised by Transmittal 1729, and Benefit Policy Manual, Chapter 6, Section 70.5. [more]
Medically Unlikely Edits and medical necessity
Kimberly Hoy previously focused on recently issued FAQ 9697. In FAQ 9697, CMS restated its position that hospitals cannot bill beneficiaries for units of service in excess of MUE limits, even when the hospital has provided an ABN to the beneficiary prior to the provision of the services subject to the MUE. CMS’s rationale is that MUEs are coding edits, not medical necessity edits. [more]
