CMS’ proposal in the 2020 OPPS proposed rule mandating the disclosure of negotiated charges between hospitals and payers may exceed the agency’s legal authority, the American Hospital Association (AHA) stated in its comments on the proposed rule.
Managers should not assume that they can review every guideline, every item in Coding Clinic, or every coding-related issue targeted by the OIG or Recovery Auditors. However, those issues that have been identified as the result of denials, external coding audits, or quality initiatives should surface to the top of the audit list for the coding manager.
While the calendar year 2020 OPPS proposed rule is shorter than in prior years (819 pages for the display version), the proposed policies therein pack a punch and may be thought of as a new day dawning for the future of hospital services.
CMS’ Hospital Outpatient Payment (HOP) panel made numerous recommendations at its annual meeting August 19 for the agency to consider ahead of the release of the 2020 OPPS final rule—with the panel and other stakeholders urging CMS to be more transparent with its responses and release of data.
Even if a hospital is not a teaching hospital, it may have services that require National Clinical Trial (NCT) reporting. It is logical for revenue integrity leadership to own this issue, but an explanation of the requirements for NCT reporting should be shared with all staff within the revenue cycle so there is a better appreciation of the fact that clinical trial billing rules apply more broadly than merely just to research or clinical trial studies.
Behavioral health is a highly specialized area of coding that many coders and billers are unfamiliar with. There are hundreds of ICD-10-CM codes for mental disorders with unique characters to specify symptoms and complications.