Providers often struggle with modifiers‑even those they've had available to report for many years‑due to the unique scenarios they face at their facilities, staffing changes, and/or unclear or lacking authoritative guidance.
CMS finalized its proposals regarding the 2-midnight rule, including moving responsibility for rule enforcement and education from Recovery Auditors to Quality Improvement Organizations (QIO). This latter change occurred October 1, 2015.
CMS and the Office of the National Coordinator (ONC) released final rules October 6 with the intention of simplifying EHR requirements and allowing providers and consumers to exchange health information with greater flexibility. This includes the final rule with comment period for the EHR incentive programs and final rule for the 2015 edition health IT certification criteria.
Provider-based clinics and departments are increasingly common, but the rules for provider-based billing can often be confusing, especially given recent changes to modifiers and place of service codes.
