One of the biggest challenges to the provider community, including hospitals and critical access hospitals (CAH), is keeping up to date with current regulatory requirements, particularly when it comes to rules on coverage, coding, billing, and payment for services provided to beneficiaries under federal healthcare programs, including Medicare and Medicaid. For those of you who have taken one of our hospital or CAH Medicare Boot Camps, you probably remember discussing this early during the week, when we identified the major official sources of authority on Medicare rules, as well as some tips about how to efficiently keep yourselves up to date.
Last week was a quiet week for CMS other than the release of the FY 2016 IPPS final rule on August 17 in the Federal Register. I thought I would take this opportunity to look at a billing issue about which I have recently been asked several questions. The questions generally revolve around how a hospital can bill for ambulance services when an inpatient leaves the facility for a procedure at another facility with the intention to return the same day. Unfortunately, since a hospital will trigger an edit that prevents the ambulance revenue code from being reported on the inpatient claim, it is assumed that the hospital must write off the transportation service. In fact, just the opposite is true based on CMS guidance.
This week CMS released guidance on the new Place of Service (POS) code for off-campus provider-based facilities, the 2-Midnight Rule, and appeals of claims denied by post-payment review contractors. Each item is short, but provides information on topics important to providers and physicians.
While many providers are still digesting the IPPS Final Rule, muddling through how the OPPS Proposed Rule might impact their bottom line, and kicking rocks because the 2-midnight rule was not chucked, President Obama signed a bill into law on August 6, 2015—and it’s one providers should note. Unanimously approved by both the House and Senate earlier this year, the Notice of Observation Treatment and Implication for Care Eligibility Act, otherwise called the NOTICE Act, will not take effect until August 2016, but will certainly add one more layer to the administrative burden associated with outpatient observation services when it does.
