Traditionally, the OPPS rulemaking cycle has been the main vehicle for changes to outpatient coding and billing regulations and policy that hospitals need to pay attention to. But increasingly, CMS has been introducing or discussing changes relevant to outpatient hospitals beyond the scope of the OPPS rules.
CMS released the fiscal year 2018 IPPS proposed rule in April, and with it came a bevy of new potential ICD-10-CM codes. The update includes a total of 406 proposed new, revised, and deleted codes to be implemented October 1, 2017.
Kidney disease is a challenging component to inpatient and outpatient care, incurring significant costs and negative outcomes. CMS and other agencies that measure our quality and cost efficiency use ICD-10-CM codes based on provider documentation and billing to ascertain that a patient has a designated kidney anatomic or functional illness in their risk-adjustment methodologies.
Reimbursement for provider-based departments (PBD) can be complex, and regulations affecting it have changed frequently over the past year. Section 603 of the Bipartisan Budget Act of 2015, the 2017 outpatient prospective payment system (OPPS) final rule, and the 21st Century Cures Act changed the payment methodology and made multiple adjustments to the definition of excepted (on-campus or grandfathered off-campus) and non-excepted (off-campus) PBDs. Hospitals must know the regulations inside and out and understand how they apply to their PBDs and to avoid denials or noncompliance.
Regulatory compliance reforms have forced CMS to set the bar high for meeting evaluation and management (E/M) standards. This is especially true for clinical documentation improvement (CDI) performance for coding and billing level four and five patient visits in outpatient settings.
The 2017 calendar year marks the beginning of a new approach to physician payment through the Quality Payment Program (QPP), an initiative created by the Medicare Access and CHIP Reauthorization Act to revise the physician payment system previously updated through the Sustainable Growth Rate.
Payment reform is here to stay. Although reimbursement will continue to evolve over the next several years, it’s unlikely that payers, commercial or government, are going to abandon risk-based models and value-based purchasing and turn the clock back to fee-for-service and volume over value.
