In several recent reports, the Office of Inspector General (OIG) determined that providers are, on average, variant from expected volumes on both short stay inpatient and long stay observation cases. What was not made clear in the OIG report is the reason why it believes such variances exist. The answer to this question likely rests within the details of how hospitals have adjusted (or not adjusted) to the use and application of “new criteria” in their daily and ongoing Medicare billing compliance processes.
Accurate clinical documentation is the bedrock of the legal medical record, billing, and coding. It is also the most complex and vulnerable part of revenue cycle because independent providers must document according to intricate and sometimes vague rules.
Recently The Joint Commission implemented an initiative, Project REFRESH, to improve processes related to pre-survey, on-site survey, and post-survey activities. Simplification, enhanced relevancy to organizations, increased transparency within the accreditation process, and the utilization of innovative approaches and technology are the goals of Project REFRESH.
Managers should not assume that they can review every guideline, every item in Coding Clinic, or every coding-related issue targeted by the Office of Inspector General or Recovery Auditor.
Back in May, CMS put a hold on short-stay inpatient audits related to the 2-midnight rule. That hold was lifted effective September 12, 2016, according to a FAQ published by CMS as CMM reported last month. Our readers are wondering, however, about the latest information when it comes to these reviews. We reached out to Ronald Hirsch, MD, FACP, CHCQM, vice president of the Regulations and Education Group at Accretive Health in Chicago, to give us the latest update.
