Q: We provide tobacco cessation services and have been reporting these with time-based HCPCS codes. There are also CPT® codes for these services. Which is the appropriate set of codes to use for Medicare?
Q: In my facility, we are supposed to send an email to our physician advisor (PA) and to administration if a query is not answered within a week. However, this policy doesn’t work well because administration does not do anything with that information, and the PA doesn’t have time to review unanswered queries. Do you have any suggestions concerning when to let a query go unanswered?
I was under the impression that CMS said it would leave the billing for self-administered drugs to the OIG. However, we have not heard anything from the OIG. What if we are not billing for the medications?
The August 2 issue of Revenue Cycle Daily Advisor included a question about benchmark conversion rates from observation to inpatient status. With regard to that question, I think it may be helpful to know the average national conversion rate and average rate for critical access hospitals. Do you have that information?
Q: If my medical waste includes PHI, do I need a BAA with our waste management vendor?
A: Yes. For example, clinics and hospitals contracting with bio-waste disposal vendors that dispose of IV bags execute a BAA with the bio-waste disposal vendors. It's no different than the requirement to execute a BAA with a document shredding vendor. If the vendor will come in contact with PHI, a BAA is in order.
Editor's note: Apgar is president of Apgar & Associates, LLC, in Portland, Oregon. He is also a BOH editorial advisory board member. This information does not constitute legal advice. Consult legal counsel for answers to specific privacy and security questions. Opinions expressed are that of the author and do not represent HCPro or ACDIS. Email your HIPAA questions to Associate Editor Nicole Votta at nvotta@hcpro.com.
