Small tweaks to the 2-midnight rule in the 2016 OPPS final rule should help providers, but a lengthy court battle related to the rule could end up making a bad situation worse.
This week’s note from the instructor is written by Debbie Mackaman, RHIA, CPCO, CCDS, regulatory specialist for HCPro and is about changes in using the modifier –CT.
Providers often struggle with modifiers‑even those they've had available to report for many years‑due to the unique scenarios they face at their facilities, staffing changes, and/or unclear or lacking authoritative guidance.
CMS finalized its proposals regarding the 2-midnight rule, including moving responsibility for rule enforcement and education from Recovery Auditors to Quality Improvement Organizations (QIO). This latter change occurred October 1, 2015.
The 2016 OPPS final rule includes the first negative payment update for the system, but CMS also listened to commenters' suggestions to make a variety of proposals less onerous either operationally or financially.
Provider-based clinics and departments are increasingly common, but the rules for provider-based billing can often be confusing, especially given recent changes to modifiers and place of service codes.
Providers need to be careful when reporting multiple services with status indicator J1 on the same claim, as NCCI logic could result in no payment for any of the reported comprehensive APC (C-APC) services.
