CMS has sharply accelerated its push toward moving outpatient payments from a fee-for-service model to a true prospective payment system with a number of its proposals in the 2016 OPPS proposed rule (https://s3.amazonaws.com/public-inspection.federalregister.gov/2015-16577.pdf), including new comprehensive APCs (C-APC) and extensive APC consolidation and reconfiguration.
Ready or not, Phase 2 of OCR's HIPAA audit program is nearly ready to begin, and healthcare organizations and their business associates (BA) should be prepared to open their books to federal regulators.
Educating coders and clinical documentation improvement (CDI) specialists on CMS claims-based measures is essential in today's value-based payment environment. Empowered with an understanding of measure specifications and risk adjustment methodologies, a strong CDI program can effectively address opportunities to improve quality profiles and associated hospital revenue.
The 2-midnight rule may get a little tweak if the proposals in CMS' 2016 OPPS proposed rule comes to fruition. The rule proposes that physicians now be granted a little more flexibility when it comes to ordering inpatient admissions, even when the stay is expected to be less than two midnights?provided of course that the stay is justifiable from a medical standpoint and the physician clearly documents his or her thinking on the case.
