Training Programs
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Regulatory MonitoringArchive for March, 2009
We would like to find out about your experiences with transition of care challenges for a research study HCPro is undertaking. We’re interested in understanding the challenges your organization faces with patients who have transitioned between multiple healthcare settings (e.g., from home health care to the hospital to a nursing home, or from a hospital to a skilled nursing facility and then back to a hospital.)
If you are interested in providing information about an actual case, please e-mail Julie McGinley at jmcginley@hcpro.com.
Of the respondents, 10 will be selected to receive a complimentary book up to $149 value from our online store! www.hcmarketplace.com/listings-M1_CAS.html.
If you haven’t already viewed the handouts from the ICD-9-CM Coordination and Maintenance Committee meeting held March 11–12, take a few moments to do so now. CMS posted various PowerPoint slides that address ICD-10 implementation, MS-DRG conversion, and ICD-10-PCS.
Visit the CMS Web site to view the information.
By Kimberly Anderwood Hoy, director of Medicare and compliance for HCPro, Inc.
This week, CMS published an MLN Matters article related to the April update to the OPPS published in Transmittal 1702 to the Claims Processing Manual. CMS made two clarifications on billing devices and supplies that might be of interest to hospitals.
The first related to surgical “kits” that contain devices that have been assigned a HCPCS code. If the kit contains only a device with a HCPCS code that maps to status indicator “N,” signifying it is packaged to the procedure payment, the hospital may include a charge for the entire kit on the line for the device HCPCS code. However, if the kit contains a device that maps to status indicator “H,” signifying it has been granted pass-through status, the hospital must separate the charges for the device and the associated supplies included in the kit.
Although there were no designated pass-through devices for CY 2009, CMS clarified that if a kit contains a device that has been granted pass-through status, the device must be billed separately from the remainder of the kit. This is very important because the payment for pass-through devices is derived from the hospital’s charge for the device, reduced to cost by applying the hospital’s cost-to-charge ratio. If the charge on the line for the device includes other supplies, in addition to the device, the payment to the hospital will include payment for the cost of the device and the other supplies. This will result, in essence, with inappropriate pass-through payment for supplies that have not been granted pass through status.
Second, CMS clarified that for any medical or surgical supplies that do not have either a “N” or “H” status indicator, the hospital should not include the HCPCS code when billing for those supplies. They provide the example of an indwelling catheter placed temporarily during surgery. An indwelling catheter has HCPCS code A4338, which maps to the status indicator “A” for an item paid under another payment system, in this case the DME fee schedule. However, in this case the catheter was used as a supply to the procedure and it would be inappropriate for the facility to be paid for the catheter separately on the DME fee schedule, because payment for the catheter was build into the payment for the surgical procedure.
This second clarification may mean that hospitals will need to have more than one charge line for these items: one charge line without the HCPCS code when used as part of a procedure or as a medical supply to a service, and a second line with the HCPCS code in the event the item is furnished as DME.
Hospitals should review the transmittal and MLN Matters article for more details on supply billing and coding. In particular, the advice regarding pass-through device kits should be retained for future reference in years when CMS does adopt pass-through devices.
CMS revises FQHC portions of State Operations Manual
On March 20, CMS issued a transmittal to change some portions of the State Operations Manual related to Federally Qualified Health Centers (FQHC).
Effective date: March 20, 2009
Implementation date: March 20, 2009
MLN Matters articles
CMS released several MLN Matters articles related to transmittals previously outlined in Medicare Weekly Update.
OIG issues review of oxaliplatin billing at Baptist Hospitals of Southeast Texas for calendar years (CY) 2004 and 2005
On March 20, the OIG issued a review of oxaliplatin billing at Baptist Hospitals of Southeast Texas for CYs 2004 and 2005. During this time, Baptist actually provided the drug darbepoetin rather than oxaliplatin, for which it billed, on two dates of service and could not support that it had provided oxaliplatin to the beneficiary for two other dates of service. Baptist received overpayments totaling $63,000 for the four dates of service.
OIG issues review of high-dollar payments for Medicare outpatient claims processed by TrailBlazer Health Enterprises for the period January 1 through December 31, 2004
On March 20, the OIG issued a review the outpatient high-dollar payments issued in 2004 by Trailblazer Health, a Medicare fiscal intermediary. The OIG found that of the 17 payments of $50,000 or more that TrailBlazer made to providers for outpatient services during 2004, five were appropriate. TrailBlazer overpaid providers for 12 claims, resulting in overpayments totaling $1.1 million.
Frequently asked questions (FAQ)
On March 18, CMS released several new/updated FAQs related to Medicare fee-for-service payment.
CMS issues memo on proposed cytology proficiency testing under CLIA
On March 13, CMS issued a memorandum related to its recently proposed regulations aimed at assuring the competency of those conducting the most common screening test for cervical cancer.
CMS issues updated interim guidance regarding the temporary mid-level staffing waiver for RHCs
On March 13, CMS issued a memorandum to provide updated guidance regarding the temporary mid-level staffing waiver for RHCs. The memo supersedes SC-09-14, issued November 21, 2008. This update will reduce burdens on existing RHCs resulting from the 1998 policy.
The Health and Human Services (HHS) department has named Dr. David Blumenthal as the national coordinator for health information technology, according to a March 20 Associated Press/Miami Herald news release. Blumenthal, who had most recently been the director of the Institute for Health Policy at The Massachusetts General Hospital/Partners HealthCare System, will help determine how to spend the $19 billion outlined in the American Recovery and Reinvestment Act of 2009 that President Obama signed into law on February 17.
Q: What will hospitals need to do to prove meaningful use and qualify for payments under the American Recovery and Reinvestment Act of 2009?
A: The Act does not specify what constitutes meaningful use, nor does it outline the type of reporting, level of interoperability, or specific quality measures. It does, however, mention several options for reporting, including surveys, attestations, and other forms, or the creation of new CPT or ICD-9/ICD-10 codes that indicate the use of an EHR. It also states that quality measures will be subject to public comment before publication in the Federal Register.
According to the Act, the Secretary of HHS will publish on the CMS Web site a list of the names of eligible hospitals that are meaningful users. Hospitals will be able to review data before it is made public.
Click here to view the Act. And stay tuned for additional coverage coming your way in the May issue of Medical Records Briefing.
CMS’ RAC provider outreach has begun, according to the schedule posted March 19 on the CMS Web site. Outreach began earlier this week in multiple regions and is scheduled through the end of May, according to the schedule. CMS will update the schedule as it adds additional outreach sessions.
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