CMS changed the status indicator for CPT code 99497 (advance care planning including the explanation and discussion of advance directives such as standard forms [with completion of such forms, when performed], by the physician or other qualified health care professional; first 30 minutes, face-to-face with the patient, family member, and/or surrogate) from N (no additional payment, payment included in line items with APCs for incidental service) to Q1 in the 2016 OPPS final rule.
Regulations adopted in October 2013 allow hospitals to bill Part B for inpatient cases that are internally reviewed and "self-denied" within one year of the date of service. But utilization review staff are unsure when to use the old condition code 44 process and when to opt for the new process using condition code W2. Operationalizing these rules can prove to be challenging, causing recoding, rebilling, and expensive slowdowns in the revenue cycle.
The utilization review (UR) process is a required process to determine if the care a physician provides the patient is medically necessary and reimbursable by the payer source. While the exact definition of medical necessity varies amongst insurers and government agencies, section 1862 (a)(1)(a) of the Social Security Act provides the basic groundwork, stating, "Notwithstanding any other provisions of this tile, no payment may be made … for any expenses incurred for items or services, which are not reasonable and necessary for the diagnosis or treatment of illness or injury or to improve the functioning of a malformed body member."
If your organization is like many others, you've probably still got some lingering questions about how to comply with the 2-midnight rule. During a recent HCPro webcast "Medical Necessity Documentation and Short Stays," Steven Greenspan, JD, LLM, vice president of regulatory affairs at Executive Health Resources in Newtown Square, Pennsylvania, and Kurt Hopfensperger, MD, JD, vice president of compliance and physician education for Executive Health Resources, tried to shed some light on areas of confusion.
A new notification requirement is coming next summer. Under the law, the Notice of Observation Treatment and Implication for Care Eligibility (NOTICE) Act, which was signed by President Barack Obama on August 6, any patient in observation who has been in the hospital for more than 24 hours must be clearly told?verbally and in writing?of his or her outpatient status. Hospital officials have to deliver this notification no more than 36 hours after the patient's outpatient treatments begin.
