Small tweaks to the 2-midnight rule in the 2016 OPPS final rule should help providers, but a lengthy court battle related to the rule could end up making a bad situation worse.
This week’s note from the instructor is written by Debbie Mackaman, RHIA, CPCO, CCDS, regulatory specialist for HCPro and is about changes in using the modifier –CT.
Regulations adopted in October 2013 allow hospitals to bill Part B for inpatient cases that are internally reviewed and "self-denied" within one year of the date of service. But utilization review staff are unsure when to use the old condition code 44 process and when to opt for the new process using condition code W2. Operationalizing these rules can prove to be challenging, causing recoding, rebilling, and expensive slowdowns in the revenue cycle.
Provider-based clinics and departments are increasingly common, but the rules for provider-based billing can often be confusing, especially given recent changes to modifiers and place of service codes.
Providers need to be careful when reporting multiple services with status indicator J1 on the same claim, as NCCI logic could result in no payment for any of the reported comprehensive APC (C-APC) services.