October 18, 2018
By David M. Glaser, Esq.
Update: Decoding “Incident to” Services
This is the definition of “incident to” for supervision requirements in hospitals. A recent RACmonitor article focused on the level of physician supervision required when services are provided “incident to” an encounter in the clinic setting. This article will focus on the level of supervision necessary in the hospital, where…
October 18, 2018
By Ronald Hirsch, MD
Inpatient Admission Order Regulations Continue to Confound
CMS removed the admission order as a condition of payment effective Oct. 1, 2018. The change in the 2019 Inpatient Prospective Payment System (IPPS) Final Rule concerning the inpatient admission order has created more controversy than I expected. When I read the proposed and final rules, wrote my RACmonitor articles…
October 11, 2018
By Knicole C. Emanuel Esq.
The Courts: Stop Recouping Alleged Overpayments
New case law supports due process for Medicare providers. Due process is one of the cornerstones of our society. Due process is the universal guarantee and found in the Fifth Amendment to the United States Constitution, which provides "No person shall…be deprived of life, liberty, or property, without due process…
October 11, 2018
By Sarah Hillegonds, Esq.
Important Guidance for Prehearing Conferences Released by OMHA
OMHA adds Chapter 14 to its case processing manual The Office of Medicare Hearings and Appeals (“OMHA”) has recently been updating its OMHA Case Processing Manual (“OCPM”). The OCPM was originally released in 2015 to regulate and codify procedures for adjudicative functions by using statutes, regulations, and OMHA directives as…
October 4, 2018
By Mark Spivey
Pre-Claim Review Demonstration Slated for December
Second iteration of demonstration poses challenge for home health providers Illinois is a state often cited as being something of a microcosm for the country, and if that is any indication, home health providers not just there, but everywhere, will want to keep an eye on the second iteration of…
October 4, 2018
By Marvin D Mitchell, RN, BSN, MBA
Aftermath of Florence Raises Concerns as Floodwaters Recede
Medicaid beneficiaries appear to be vulnerable following Hurricane Florence. The wildfires in California, as well as Hurricanes Harvey, Maria, and now Florence demonstrate and present new challenges. The intensity of the wildfires and the incredible rainfall brought far worse risks to life, property, and recovery than prior natural disasters would…
October 4, 2018
By David M. Glaser, Esq.
Decoding “Incident to” Physician Services
The definition of “incident to” for physician services remains confusing. Medicare uses the term “incident to” as shorthand for services that are “incident to a physician’s services.” The term would be confusing enough if its meaning was always the same, because conceptualizing what sorts of services are “incident to a…
September 27, 2018
By Duane Abbey, PhD, CFP
Medicare Payment Perspective: Is Healthcare Really a Business?
CMS is encouraging the integration of healthcare providers so that their size is increased to have averaged payments represent a break-even or better. CMS (the Centers for Medicare & Medicaid Services) views payment from a national perspective on a statistically averaged basis. Individual providers such as physicians, clinics, hospitals, home…
September 27, 2018
By Marvin D Mitchell, RN, BSN, MBA
Hospice Transfer Seen as a Reduction in Hospital DRG Payment
Providers should consider how to optimize the patient’s health status prior to discharge to hospice. In his RACmonitor article of Aug. 8 regarding the recent proposed final rule for inatient amission orders, Dr. Ronald Hirsch reported that the Centers for Medicare & Medicaid Services (CMS) added inpatient transfers to hospice…
September 27, 2018
By Timothy Powell, CPA CHCP
Changes in Readmission Adjustment Factors
In FY 2019, hospital performance in the HRRP will be assessed relative to hospitals within the same peer groups. Since 2013, Medicare has penalized hospitals that have an “excessive” number of readmissions under a program called the Hospital Readmissions Reduction Program, or HRRP. The Centers for Medicare & Medicaid Services…
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