Search Publications:
Payment Matters
July 27, 2011
CMS Proposes Physician Payment Reductions for Services Within Hospital Three-Day Payment Window
By: Thomas W. Coons
In its recently proposed Calendar Year 2012 Physician Fee Schedule (PFS) Update [PDF], 76 Fed. Reg. 42772, 42914-42917 (July 19, 2011), the Agency proposes to expand the three-day payment window policy to include physician practices that are wholly-owned or wholly-operated by hospitals. More specifically, CMS proposes to reduce Medicare payment to physicians under the PFS where, within three days of receiving the physician service, the patient is admitted to a hospital that wholly owns or wholly operates the physician practice. The proposed rule, if implemented, will be effective for services furnished on or after January 1, 2012.
Click to continue...CMS Proposes Refinement of Outpatient Supervision Rules for Therapeutic Services
By: Thomas W. Coons
In its recently proposed Calendar Year 2012 Hospital Outpatient PPS (OPPS) payment rule [PDF], 76 Fed. Reg. 42170, 42277-42285 (July 18, 2011), which CMS recently put on its web page, CMS proposes refinements to its hospital outpatient physician supervision policies. First, CMS proposes to state clearly in the regulatory text at 42 C.F.R. § 410.27 that all hospital outpatient therapeutic services are subject to that section’s payment limitations, including the direct supervision requirement. Additionally, CMS clarifies that hospitals are not permitted to furnish therapeutic services or surgery to their patients under arrangements with ASCs. As justification for this position, CMS states that it does not make provider-based determinations for ASCs under 42 C.F.R. § 413.65(a)(1)(ii)(A) and that under 42 C.F.R. § 410.27(a)(1)(iii), therapeutic services must be furnished in provider-based space. As a result of these two provisions, ASCs may not be a provider-based department of a hospital pursuant to the regulations and their services, consequently, may not be covered as therapeutic hospital services under 42 C.F.R. § 410.27.
Click to continue...CMS Proposes Ambulatory Surgical Center Quality Reporting – and Eventual Medicare Reimbursement Reduction – Rule
The Medicare Hospital Outpatient Prospective Payment System (OPPS) for calendar year 2012 includes the proposed Ambulatory Surgical Center Quality Reporting Program [PDF]. The proposed ASC QRP will require each ASC to report seven claims-based elements beginning on January 1, 2012, and, if not reported, an ASC could receive a reduction in Medicare reimbursement of up to 2% as early as calendar year 2014. The ASC QRP would require each ASC to report additional elements in 2013 and 2014 that, if not reported, could reduce that ASC’s Medicare reimbursements in 2015 and 2016. Comments on the proposed ASC QRP are due by September 16, 2011.
Click to continue...CMS Proposes Community Mental Health Centers Conditions of Participation
The Centers for Medicare and Medicaid Services (CMS) published proposed conditions of participation (COP) for community mental health centers (CMHC) in the Federal Register on June 17, 2011. The proposed rule can be located at: www.gpo.gov/fdsys/pkg/FR-2011-06-17/pdf/2011-14673.pdf. The proposed rule, if finalized, would create the first set of COPs that CMHCs would need to satisfy to participate in the Medicare program. Issues addressed in these proposed COPs include restrictions on professionals who deliver care, client rights, the use of restraints, and the administration and governance of CMHC services. The open comment period for the proposed rule will close on August 5, 2011.
Click to continue...HIPAA - National 5010 Testing Days are Underway
By: Joshua J. Freemire and James B. Wieland
As part of the upcoming transition to the 5010 transaction standards (which will replace the existing version of the X-12 standards for all HIPAA covered entities) CMS has organized “National 5010 Testing Days.” CMS has explained that the testing days will encourage collaboration between providers and the Medicare Administrative Contractors (MACs) by allowing providers to “to come together and test compliance efforts that are already underway with the added benefit of real-time help desk support and direct and immediate access to MACs.”
Click to continue...
