Organizations and CDI specialists must have a thorough understanding of how regulations and guidelines impact risk adjustment in the outpatient setting. A misinterpretation can easily lead to inadvertent upcoding—and that can lead to costly audits, settlements, and accusations of fraud.
CMS' 340B FAQ reviews modifiers -JG (drug or biological acquired with 340B drug pricing program discount) and -TB (drug or biological acquired with 340B drug pricing program discount, reported for informational purposes) and requires 340B hospitals to report modifiers even on drugs that are not subject to the discount policy.
In May, we expect to see the release of the International Classification of Diseases, 11th Edition, for Mortality and Morbidity Statistics (ICD-11-MMS) by the World Health Organization. Work will then begin in the U.S. to adapt it for our clinical use as ICD-11-CM. Hopefully, with the benefit of foresight and lessons learned from the past, we will not reenact the pain we all had with the ICD-10-CM/PCS implementation.
If ICD-10-CM/PCS is used to its full potential, it will provide greater detail and a more accurate depiction of patient severity. This level of detail is expected to provide more information about the relationship between a provider’s performance and the patient’s condition.
CMS’ policy in the 2018 OPPS final rule to cut reimbursement for drugs purchased through the 340B drug discount program by nearly 30%, accounting for the decrease from average sales price plus 6% to minus 22.5%, is getting a lot of attention from the provider community—and with good reason.
