While the 2017 OPPS proposed rule includes a variety of tweaks and augmentations to existing regulations, its biggest impact is likely to come from its proposal to implement Section 603 provisions of the Bipartisan Budget Act of 2015 regarding off-campus, provider-based departments (PBD) and move toward more site-neutral payment policies.
CMS’ introduction of CMS-1455-R in March 2013 allowed hospitals to ignore the one-year timely filing deadline and rebill admissions that were denied by an auditor, even many years after the date of service. Fast forward to October 29, 2015, when the OIG released a policy stating that hospitals may waive the cost of self-administered medications to Medicare beneficiaries without concern about inducement or kickback accusations if the hospital develops a policy and applies it uniformly.
CMS’ proposed changes to implement Section 603 of the Bipartisan Budget Act of 2015 and reshape payments for off-campus, provider-based departments represent the most significant changes in the current year 2017 OPPS proposed rule.
I was under the impression that CMS said it would leave the billing for self-administered drugs to the OIG. However, we have not heard anything from the OIG. What if we are not billing for the medications?
Healthcare organizations have become mass gatherers of data. But without sophisticated analytics, integrated IT tools, and processes to mine that data, they may not be able to take advantage of it.
