This week’s Medicare updates include a transmittal recurring update notification describing changes to and billing instructions for various payment policies implemented in the October 2016 OPPS update; news about CMS once again allowing some providers to settle inpatient status claims in appeals; an OIG report regarding the improper payment of millions of dollars for unlawfully present beneficiaries; and more!
I recently heard of a local long-term care hospital (LTCH, also known as LTACH) that was unwilling to accept military veterans who were cared for at her facility or any Veterans Affairs hospitals even though they would otherwise qualify for LTCH care. The reason the LTCH would not accept these patients was because they did not have a preceding visit in a “regular” hospital. What's the solution?
Hospitals got a last-minute reprieve from the MOON notification requirement, which was set to go into effect August 6. Citing the need for additional time to revise the standardized notification form that hospitals will need to use to notify patients about the financial implications of being assigned to observation services, CMS moved back the start date for the requirement in the 2017 Inpatient Prospective Payment System (IPPS) final rule to "no later than 90 days," after the final version of the form is approved.
One of the topics raising the most questions in case management today is related to the MOON notification requirement. Hospitals were struggling this summer to comply with the Notice of Observation Treatment and Implication for Care Eligibility (NOTICE) Act, which was signed by President Barack Obama August 6, requiring hospitals to provide a verbal and written notice of outpatient status to any patient in observation who has been in the hospital for more than 24 hours. Just prior to the August 6 implementation date, hospitals received word that the notification requirement would be delayed pending approval of modifications made to the government's notification form.
