The Joint Commission continues to provide excellent resources to help healthcare organizations stay ready for surveys, as well as resources that help them meet and understand the intent of standards and elements of performance.
Whether it is the CPT Manual or Chapter 12 of the Medicare Claims Processing Manual, the definition of a “new patient” is the same for physicians and nonphysician practitioners billing. But that doesn't mean coding and billing for E/M services is clear cut.
As CMS and third-party payers have looked for ways to treat patients in the outpatient setting and reduce inpatient volumes, CMS has used the 2-midnight rule, in addition to other methods, to treat patients as outpatients or in observation whenever possible.
Accurate clinical documentation is the bedrock of the legal medical record, billing, and coding. It is also the most complex and vulnerable part of the revenue cycle.
CMS issued SE1609 to clarify long-standing policy concerning external infusion pumps. Apparently, both freestanding physician offices and outpatient hospital departments were treating external pumps as an item of durable medical equipment, even when the physician or hospital department set up the pump on the patient, supplied the drug, and programmed the infusion rate and dose into the pump.
There is an extensive list of coverage requirements that must be met to furnish outpatient services to Medicare beneficiaries. Hospitals may find that certain coverage requirements for therapeutic and diagnostic service are more difficult to meet than others, especially in off-campus provider-based departments.
