As part of the 2013 OPPS final rule, CMS finalized a clarification to 42 CFR 419.2(b) that could cause confusion in the future if hospitals are audited by third-party payers or by Medicare contractors who do not fully understand the intent of the language or how CMS develops payment rates, says Jugna Shah, MPH, president of Nimitt Consulting based in Washington, D.C.
Hospitals earned a big win with drug payments this year in the 2013 OPPS final rule, released November 1. CMS decided to finalize its proposal to follow the statute and reimburse facilities at the average sales price (ASP) plus 6%.
Despite efforts to prevent data breaches in healthcare, they continue to cause alarm. Almost 20 million patient health records have been compromised in the past two years, according to statistics from HHS.
There are six generic approaches to managing risk, and the approach an organization chooses to use will depend on many factors. For example, how real is this risk? Can it actually become a problem, or is it merely theoretical? Management will want to decide whether the risk is likely to happen and whether it is possible to determine when it may happen. This will also assist in appropriate allocation of resources to focus on material risk areas.
