As federal agencies release new and complex regulations for acute and postacute care facilities, providers are faced with the daunting task of unraveling and complying with the latest changes while ensuring patients receive quality care.
Section 216(a) of the Protecting Access to Medicare Act of 2014 (PAMA) added a requirement that will dramatically revise the Medicare Clinical Laboratory Fee Schedule (CLFS) effective January 1, 2018.
While the 2018 OPPS final rule may be controversial for its payment cuts to drugs purchased through the 340B drug discount program, it contains several provisions supported by hospitals and other stakeholders.
Physicians may be angry at the increased documentation, coding, and billing workflow and compliance activities they must perform to be successful in new reimbursement models. However, to avoid accustations of fraud and upcoding, they must develop their own OIG-recommended compliance plan and be open to rigorous feedback and advice.
Currently, there are no national guidelines for how facilities should assign evaluation and management (E/M) levels in the emergency department (ED). Under Medicare’s ambulatory payment classification (APC) system, facilities create their own internal guidelines for determining the ED visit level, and each facility must follow its own system to demonstrate compliance.
The focus of FY 2018 code changes is specificity. Payers now expect codes to reflect the exact diagnosis and care given before claims will be reimbursed. Increased granularity in both clinical documentation and coding is critical for revenue cycle success in the year ahead.
A new effort is underway to allow observation stays to count toward the three-day stay required by CMS to qualify for reimbursement for a postacute skilled nursing facility stay.
Despite opposition from many stakeholders, a bipartisan contingent of Congress, and CMS’ own advisory panel, the agency is moving forward with its plan to drastically cut payments for drugs acquired through the 340B drug discount program, according to the 2018 OPPS final rule, released November 1.
The largest source of estimated revenue loss in the healthcare midcycle in 2016 was attributed to inadequate documentation, according to a report by the Advisory Board. The report analyzed a range of hospitals in varying size, from 0–500 beds, to determine the impact of midcycle functions. The revenue loss reported for an average 250-bed hospital was $2–$5.5 million.
