Ochsner Clinic Foundation began its ambulatory clinical documentation excellence journey in 2004, when Medicare implemented its Hierarchical Condition Categories (HCC). Since HCCs affect patients’ Risk Adjustment Factor scores, and ultimately reimbursement for the care required to treat sicker patients, Ochsner needed to determine the best way to ensure annual HCC capture for all patients across its vast system.
CMS issued SE1609 to clarify long-standing policy concerning external infusion pumps. Apparently, both freestanding physician offices and outpatient hospital departments were treating external pumps as an item of durable medical equipment, even when the physician or hospital department set up the pump on the patient, supplied the drug, and programmed the infusion rate and dose into the pump.
There is an extensive list of coverage requirements that must be met to furnish outpatient services to Medicare beneficiaries. Hospitals may find that certain coverage requirements for therapeutic and diagnostic service are more difficult to meet than others, especially in off-campus provider-based departments.
This week’s Medicare updates include National Coverage Analysis for Supervised Exercise Therapy for Symptomatic Peripheral Artery Disease; ICD-10 coding revisions to National Coverage Determinations; the July 2017 OPPS quarterly update; and more!
Reimbursement for provider-based departments (PBD) can be complex, and regulations affecting it have changed frequently over the past year. Section 603 of the Bipartisan Budget Act of 2015, the 2017 outpatient prospective payment system (OPPS) final rule, and the 21st Century Cures Act changed the payment methodology and made multiple adjustments to the definition of excepted (on-campus or grandfathered off-campus) and non-excepted (off-campus) PBDs. Hospitals must know the regulations inside and out and understand how they apply to their PBDs and to avoid denials or noncompliance.
