In November 2014, CMS put its certification requirement under the 2-midnight rule to bed, finally conceding that the rule was creating more problems than it solved. While many frustrated case managers celebrated this development, they still aren't completely off the hook. CMS replaced the global certification requirement with two more-specific certification requirements that went into place on January 1, and case managers need to be aware of them.
Even before ICD-10-CM was delayed until October 1, 2015, the quality of physician documentation to accommodate the new code set was a top concern for the healthcare industry.
Organizations often struggle to finalize charts after discharge so they can be coded in a timely manner, but this process can be completed efficiently with direction from HIM professionals and coordination between departments.
The policies that CMS publishes each year in the OPPS proposed rule don't always come as a surprise. Sometimes, CMS will announce its future intent in a previous rule in order to notify providers about data it is looking at or requesting comments on.
When CMS introduced the -X{EPSU} modifiers in August 2014 to be used in specific instances to replace modifier -59 (distinct procedural service), the agency encouraged "rapid migration" to the new modifiers.
