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OCR proposes modifications to HIPAA privacy rule
On October 1, the Office for Civil Rights (OCR) issued a display copy of proposals to modify the HIPAA privacy rule. The proposed rule would strengthen privacy protections for genetic information, as required by the Genetic Information Nondiscrimination Act of 2008.
CMS issues IRF PPS correction
On October 1, CMS issued a correction in the Federal Register to its previously issued inpatient rehabilitation facility (IRF) PPS final rule for 2010.
Editor’s note: Judith Kares, JD, CPC, regulatory specialist for HCPro, Inc., is the author of this week’s note from the instructor.
The Office of Inspector General (OIG) of the Department of Health and Human Services has just released its Work Plan for FY 2010. A number of significant issues relating to hospital services covered under Parts A and B are targeted for review.
OIG issues Work Plan
On October 1, the OIG issued its Work Plan for FY 2010.
Editor’s note: Debbie Mackaman, RHIA, CHCO, regulatory specialist for HCPro, Inc., is the author of this week’s note from the instructor.
After CMS issued Transmittal 1803, we have continued to receive questions on the correct way to bill for outpatient services when Condition Code 44 criteria have been met. The next chapter of the story involves determining if and when observation begins.
Click over to the MedicareMentor Blog to read more.
CMS rescinds, replaces LCD exception transmittal
On September 25, CMS replaced its previous transmittal on LCD exceptions. It had previously sent out the incorrect version of section 3.12. All other material remains the same.
Effective date: October 13, 2009
Implementation date: October 13, 2009
CMS replaces FDG PET transmittals
On September 18, CMS rescinded and replaced two previous transmittals related to FDG PET coverage.
Effective date: April 6, 2009
Implementation date: October 19, 2009
By Debbie Mackaman, RHIA, CHCO, regulatory specialist for HCPro, Inc.
On September 11, CMS published Transmittal 302 that updated the Program Integrity Manual on Local Coverage Determination (LCD) exceptions. When specific authorized contractors conduct a complex medical review, they have the authority (in rare and unusual circumstances) to apply an exception to the “reasonable and necessary” requirements described in an LCD to approve or deny a claim. However, they cannot make exceptions to National Coverage Determinations (NCDs). In addition, and unless otherwise directed by CMS, RACs can only use the exceptions process to not deny a claim. This is a good time to review the difference between a national and a local coverage determination policy.
Click over to the MedicareMentor Blog to read more.
By Judith Kares, JD, CPC, regulatory specialist for HCPro, Inc.
Last month, I participated in an HCPro audioconference on HINNs. "HINN" stands for hospital-issued notice of non-coverage. It’s the inpatient equivalent of an advanced beneficiary notice (ABN).
Under Medicare’s limitation on liability (LOL) provisions, hospitals are required to provide prior notice, in a prescribed form, when certain outpatient or inpatient services ordered by a physician do not meet Medicare’s medical necessity guidelines for the patient’s condition.
In such cases, the ABN is the prescribed form of prior notice for outpatient services, while the HINN is the prescribed from of prior notice for inpatient services. Although the prior notice requirements for LOL have been in place for a number of years, hospitals continue to struggle to provide timely, appropriate notification, particularly in the inpatient setting.
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