Hospital providers will need to look beyond the OPPS proposed rule for policies regarding 2018 reimbursement, as the 2018 Medicare Physician Fee Schedule proposed rule includes a policy that could once again have significant payment impact on non-excepted, off-campus provider-based departments.
The 2018 OPPS proposed rule is one of the shortest, and latest, in recent memory being released July 13 at only 663 pages, but it contains major proposed policy changes for the 340B drug discount program, new modifiers, and expands packaging to drug administration for the first time.
The display copy of the Quality Payment Program proposed rule was released in June, and you can think of this rule as a companion to the Medicare Physician Fee Schedule that typically comes out with the OPPS rule. That means both rules need to be read, understood, and, ideally, commented on by providers.
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.
