CMS comment submitted by American Osteopathic Association representatives on AMA RUC September 5, 2018, with tracking number: 1k2-9592-adpg Starting 2019, the Centers for Medicare & Medicaid Services (CMS) proposes enacting Multiple Procedure Payment Reduction (MPPR) if an evaluation and management (E/M) service and procedure are performed on the same date of service. Citing abuse of […]
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Tag Archives: Comment
CMS seeks comment on RUG-IV replacement
Comment to CMS: History Documentation Optional? Let the Patient Co-author the History
During a July 18, 2018 CMS Twitter™ podcast, CMS National Coordinator for Health Information Technology, Donald Rucker, M.D. defended the new CMS 2019 proposal to make documentation of the History optional for health records. He was asked, “In light of technology’s thirst for data to identify best practices and construct predictive algorithms, is it possible […]
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CMS seeks public comment on new proposed Medicare application process
COMMENT TO CMS: Do Not Remove History and Examination Documentation Requirements
A new Centers for Medicare and Medicaid Services (CMS) proposal suggests removing documentation requirements for the History and Examination components of a medical encounter. [i] [ii] CMS rationalizes the change because 1995 and 1997 Evaluation and Management Guidelines are “administratively burdensome” and “too complex.” Rather than mandate documentation of the History and Exam, CMS proposes […]
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CMS gives providers a chance to comment on 2-midnight rule payment methodology
By Steven Andrews
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.
A suit brought by the American Hospital Association (AHA) and other hospital associations and organizations against CMS recently resulted in the court ruling that CMS had to provide information on how it calculated a negative 0.2% reduction in inpatient payment rates as a result of implementing the 2-midnight rule. The court also said that providers should have an opportunity to comment on the calculation.
In early December, CMS released a notice with comment period to meet the court’s requirement, but providers might not be pleased with forcing the agency’s hand. CMS notes that when originally estimating the number of outpatient cases that should shift to inpatient as a result of the rule, it looked at 2011 claims containing HCPCS codes G0378 (hospital observation service, per hour) and G0379 (direct admission of patient for hospital observation care).
Using this data, CMS identified approximately 350,000 observation stays that lasted two or more midnights. The agency combined that with approximately 50,000 claims that contained major procedures based on APCs that resulted in stays lasting more than two midnights. CMS also analyzed data from the inpatient side by looking at inpatient claims containing surgical MS-DRGs with stays that lasted less than two midnights and found approximately 360,000.
The agency used this data to determine a net increase of 40,000 inpatient discharges as a result of the rule to calculate $ 220 million in increased expenditures on the inpatient side, leading to the reduction.
However, CMS now says that in light of new regulations and by using different metrics to estimate the shift, as many as 570,000 cases could move to the inpatient side, resulting in an even larger payment shift.
Providers are encouraged to comment on the rule in order to let CMS know what the best method for estimating these cases would be. This could have a large impact on payments, so if you’re interested in commenting, head to regulations.gov and make a submission by February 2, 2016.
CMS Extends Comment Period for SNF PPS Case-mix Revisions
If you haven’t commented on the notice of proposed revisions to the Skilled Nursing Facility Prospective Payment System (SNF PPS) case-mix methodology, it’s not too late. The Centers for Medicare & Medicaid Services (CMS) just granted an extension to the comment period. In an Advanced Notice of Proposed Rulemaking (ANPRM) with commend period, published in the Federal Register on […]
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