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.
Assigning the correct patient status is important not only to ensure that the hospital gets accurate payment for a patient stay, but also to ensure that the patient receives access to the postacute benefits to which he or she is entitled.
Q: When our pharmacy mixes medications for infusion, they sometimes have to waste a part of the vial that was opened. They log this in the pharmacy log, which they keep in the department. We have been billing the full amount of the drug that was in the vial and have had no issues with getting paid. Our pharmacist came from a regional meeting and told us that this is going to change.
