CORRECTION: Because of a publishing error, this article, written by healthcare attorney David Glaser, was published on May 30 by RACmonitor after the new guidance was actually published.
That guidance can be found here, https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/QSO-19-13-Hospital.pdf
In a statement to RACmonitor, Glaser offered comments about the new guidance from the Centers for Medicare & Medicaid Services (CMS).
“While there were some positives in the new guidance, including clarity that shared waiting rooms are acceptable, on the whole it is rather disappointing,” Glaser wrote in an email to RACmonitor. “This new guidance, while better than the current position taken by regional offices, is inconsistent with both the wording and spirit of the regulation.”
According to Glaser, there is a legitimate policy concern that underlies the guidance: preventing situations where patients are surprised by hospital co-payments when they expected to be treated like clinic patients. The provider-based rules require that the facility make the patient aware that they are in hospital space, a requirement that Glaser said is fair.
“The new guidance, however, focuses on things like the paths of various corridors, suggesting that if a hallway goes through clinical space the hallway may not be used by patients from a different provider,” Glaser said. “That principle is difficult to apply and completely unrelated to the policy of making sure patients know they’ll receive a hospital bill.”
Glaser’s point is that whether a particular corridor goes through or around a unit seems like an arbitrary way to decide whether or not entities can share space. The difference, Glaser said, is between a hallway that goes “through” a lab compared to one that goes “past” a lab may be Talmudic, but it does not seem like a way to determine whether medical care should be covered.
“The good news is that CMS is allowing public comment on this policy,” Glaser said. “Comments can be made until July 2. I know Fredrikson & Byron will be putting together comments on behalf of its clients. I encourage listeners to do the same. We will be suggesting that the emphasis return to patient awareness, not issues like whether medical records are shared.”
The Centers for Medicare & Medicaid Services (CMS) issued the review copy of the Fee Schedule, Friday, Nov. 1. Usually, the final copy appears about
Some of you may have noticed that I am not always very nice to some insurance companies. And deservedly so. But I also point out
Please log in to your account to comment on this article.
Optimize your outpatient clinical documentation and gain comprehensive knowledge from foundational practices to advanced technologies, ensuring improved patient care and organizational and financial success. This webcast bundle provides a holistic approach to outpatient CDI, empowering you to implement best practices from the ground up and leverage advanced strategies for superior results. You will gain actionable insights to improve documentation quality, patient care, compliance, and financial outcomes.
Enhancing outpatient clinical documentation is crucial for maintaining accuracy, compliance, and proper reimbursement in today’s complex healthcare environment. This webcast, presented by industry expert Angela Comfort, DBA, RHIA, CDIP, CCS, CCS-P, will provide you with actionable strategies to tackle complex challenges in outpatient documentation. You’ll learn how to craft detailed clinical narratives, utilize advanced EHR features, and implement accurate risk adjustment and HCC coding. The session also covers essential regulatory updates to keep your documentation practices compliant. Join us to gain the tools you need to improve documentation quality, support better patient care, and ensure financial integrity.
This webcast, presented by Angela Comfort, DBA, RHIA, CDIP, CCS, CCS-P, a recognized expert with over 30 years of experience, offers essential strategies to improve outpatient clinical documentation integrity. You will learn how to enhance the accuracy and completeness of patient records by adopting best practices in coding and incorporating Social Determinants of Health (SDOH). The session also highlights the role of technology, such as EHRs and CDI software, in improving documentation quality. By attending, you will gain practical insights into ensuring precise and compliant documentation, supporting patient care, and optimizing reimbursement. This webcast is crucial for those looking to address documentation gaps and elevate their coding practices.
ICD10monitor has teamed up with renowned CDI expert Dr. Erica Remer to bring you an exclusive webcast on how to recognize sepsis, how to get providers to give documentation that will support sepsis, and how to educate to avert sepsis denials. Register now and become a crucial piece of the solution to standardizing sepsis clinical practice, documentation, and coding at your facility.
Dr. Ronald Hirsch provides critical details on the new Medicare Appeal Process for Status Changes for patients whose status changes during their hospital stay. He also delves into other scenarios of hospital patients receiving custodial care or medically unnecessary services where patient notifications may be needed along with the processes necessary to ensure compliance with state and federal guidance.
Healthcare organizations face complex regulatory requirements under the No Surprises Act and Price Transparency rules. These policies mandate extensive fee disclosures across settings, and confusion is widespread—many hospitals remain unaware they must post every contracted rate. Non-compliance could lead to costly penalties, financial loss, and legal risks. Join David M. Glaser Esq. as he shows you how to navigate these regulations effectively.
Protect your facility from unwanted audits! Join Becky Jacobsen, BSN, RN, MBS, CCS-P, CPC, CPEDC, CBCS, CEMC, and take a deep dive into both the CMS and AMA guidelines for reporting post operative pain blocks. You’ll learn how to determine if the nerve block is separately codable with real life examples for better understanding. Becky will also cover how to evaluate whether documentation supports medical necessity, offer recommendations for stronger documentation practices, and provide guidance on educating providers about documentation requirements. She’ll include a discussion of appropriate modifier and diagnosis coding assignment so that you can be confident that your billing of post operative pain blocks is fully supported and compliant.
During this RACmonitor webcast Dr. Ronald Hirsch spotlights the areas of the OIG’s Work Plan and the findings of their most recent audits that impact utilization review, case management, and audit staff. He also provides his common-sense interpretation of the prevailing regulations related to those target issues. You’ll walk away better equipped with strategies to put in place immediately to reduce your risk of paybacks, increased scrutiny, and criminal penalties.
Copyright © 2024 RACmonitor. Powered by MedLearn Media.
Happy National Doctor’s Day! Learn how to get a complimentary webcast on ‘Decoding Social Admissions’ as a token of our heartfelt appreciation! Click here to learn more →
👻Spooky Sale is Back!👻 Get 31% off all three Medlearn brands, using code SPOOKY24.
