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.
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.
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.
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.
Ochsner Clinic Foundation began its ambulatory clinical documentation excellence journey in 2004, when Medicare implemented its Hierarchical Condition Categories (HCC). Since HCCs affect patients’ Risk Adjustment Factor scores, and ultimately reimbursement for the care required to treat sicker patients, Ochsner needed to determine the best way to ensure annual HCC capture for all patients across its vast system.
