CMS has changed its selection process for medical records for short-stay reviews under the 2-midnight rule. This could be problematic for some organizations, says Ronald Hirsch, MD, FACP, CHCQM, vice president at R1 Physician Advisory Services in Chicago.
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.
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.
