If the 2-midnight rule keeps you up at night, it might help to add some PEPPER to your processes. CMS recently updated PEPPER, otherwise known as the Program for Evaluating Payment Patterns Electronic Report, to provide hospitals with insight into how well they're doing with 2-midnight rule compliance.
CMS has instructed MACs to reprocess claims and providers to reimburse beneficiaries due to a miscalculated copayment for stereotactic radiosurgery, according to the October update to the OPPS and Integrated Outpatient Code Editor (I/OCE).
To fully understand where your organization's risks lie, you not only need to have a firm grasp on risk analysis and assessment processes, you need to define these processes as well.
You hear it over and over again. Covered Entity (CE) A failed to produce an ongoing risk assessment for HIPAA security compliance. CE B had an incomplete risk analysis, leading to a failure to recognize security weaknesses and vulnerabilities. And in come the fines.
