The American Hospital Association asked CMS to clarify some aspects of its new outpatient notification requirement, Notice of Observation Treatment and Implication for Care Eligibility Act, which is supposed to go into effect in the summer of 2016.
Now that you've had time to recover from the first hectic months of the new year, it's time to focus on what the remainder of the year will bring for case management and some of the biggest challenges that may lie ahead in 2016.
Discharge planning Conditions of Participation changes.Ronald Hirsch, MD, FACP, CHCQM,vice president of the Regulations and Education Group at Accretive Health in Chicago, called CMS' proposed changes to the discharge planning Conditions of Participation (CoPs), which would revamp the discharge planning process, "the bombshell for 2016."
BFFC-QIO audits. In October 2015, Quality Improvement Organizations (QIO) took over the role of education and enforcement for the 2-midnight rule from the Recovery Audit Contractors. In 2016, these Beneficiary and Family Centered Care QIO (BFCC-QIO) audits of short stays will be in full force, says Hirsch.
The new Comprehensive APC for observation patients. CMS approved a new comprehensive APC (C-APC) payment for observation patients for 2016, which provides payment for nonsurgical services provided to patients with an eight-hour or longer observation stay. Any ED-visit level code will qualify for the comprehensive APC code. "The new Comprehensive APC for observation patients means that hospitals need to be more efficient and avoid incidental testing which will no longer be paid," says Hirsch.
To find the right solution for your organization, you must understand how and why employees are using messaging and email services.
"You want a solution that's easy to use, and that's within the work environment of whoever is sending the message," Apgar says. Apgar's case in point is Oregon's state-sponsored CareAccord Direct Secure Messaging email service. The service doesn't connect to all EHRs or an organization's email service. Users have to log in through the website to send a message. Busy employees, he points out, particularly clinical staff like physicians, are unlikely to use a service that requires them to go out of their way, making it a poor choice.
Text messaging solutions directed at the healthcare industry were not always common and user friendly. Until about a year ago, there were few mature products on the market for securing text messages, Apgar says. The ones that did provide good security had serious usability limitations as most could only be used to communicate with other people in your network. A specialist, Apgar says, wouldn't have been able to send a quick, secure text to his or her patient's primary care doctor if the doctor was not part of the specialist's organization. Some services, like Tiger Text and HipaaChat, offer a solution to this problem. (See the March 2015 issue of BOH for more information about Tiger Text.) If the sender uses Tiger Text, but the recipient does not, Tiger Text delivers a text message that includes a link to the now encrypted text message. When the recipient clicks the link, the browser on the mobile device opens up to the text message, which is encrypted at a National Institute of Standards and Technology standard 256-bit encryption.
Keep in mind, however, that you have to treat text messaging the same as email. Device security and storage need to be analyzed. Burton warns that some may not realize the text messages on their phones leave traces of data behind.
Apgar agrees. "They don't understand that ultimately the cell phone carrier has servers that back up your texts, and you have it [stored] on your phone," he says.
by Shannon Newell, RHIA, CCS, AHIMA-approved ICD-10-CM/PCS trainer
Approximately 800 hospitals across the country that perform inpatient total hip and knee joint replacements will be required to participate in the latest value-based payment initiative launched by CMS, the Comprehensive Care for Joint Replacement (CJR) model, which becomes effective April 1.
A recent Healthcare Financial Management Association webinar on the CJR noted it as one of the biggest Medicare changes since the implementation of diagnosis-related groups (DRG). Not surprisingly, various impacted parties continue to push for delays in implementation of the model. The CJR model holds participant hospitals financially accountable for the cost and quality of an episode of care and incentivizes increased coordination of care among hospitals, physicians, and postacute care providers.
The assignment of ICD-10 codes on both inpatient and outpatient claims impacts these outcomes by triggering which discharges are included in the program, the actual (or observed) complication rates for these patients, and?equally important but often overlooked?their risk-adjusted expected complication rates. If ever there was an opportunity for clinical documentation improvement (CDI) programs to step up to support their organizations with documentation that impacts both quality and financial outcomes, this is it!
