Whether it is the CPT Manual or Chapter 12 of the Medicare Claims Processing Manual, the definition of a “new patient” is the same for physicians and nonphysician practitioners billing. But that doesn't mean coding and billing for E/M services is clear cut.
The display copy of the Quality Payment Program proposed rule was released in June, and you can think of this rule as a companion to the Medicare Physician Fee Schedule that typically comes out with the OPPS rule. That means both rules need to be read, understood, and, ideally, commented on by providers.
As CMS and third-party payers have looked for ways to treat patients in the outpatient setting and reduce inpatient volumes, CMS has used the 2-midnight rule, in addition to other methods, to treat patients as outpatients or in observation whenever possible.
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.
