The 2016 OPPS proposed rule is likely to continue CMS' trend of expanded packaging and feature refinements and expansion of comprehensive APCs based on comments CMS has made in prior rules.
Modifier -25 (significant, separately identifiable E/M service by the same physician on the day of a procedure) is used to distinguish visits from procedures on the same day.
It is not used to distinguish observation from a visit service on the same day.
While many providers are still digesting the IPPS Final Rule, muddling through how the OPPS Proposed Rule might impact their bottom line, and kicking rocks because the 2-midnight rule was not chucked, President Obama signed a bill into law on August 6, 2015—and it’s one providers should note. Unanimously approved by both the House and Senate earlier this year, the Notice of Observation Treatment and Implication for Care Eligibility Act, otherwise called the NOTICE Act, will not take effect until August 2016, but will certainly add one more layer to the administrative burden associated with outpatient observation services when it does.
The role of the utilization review (UR) committee has changed as facilities transition from reporting condition code 44 for concurrent reviews to condition code W2 for post-discharge reviews.
As we await more instructions from CMS on implementation of the OPPS and MPFS final rule, I thought I would take this time to let those who missed the CMS notice know that they will be hosting another National Provider Call on Tuesday, January 14th from 1:30 to 3:00 p.m. EST.Click the link above for more information and an in-depth analysis.
