Update on Shared Decision-Making for Defibrillators

Original story posted on: March 7, 2018

  • Product Headline: Cardiac Procedures Two-Part Series: Don't Leave Any Money on the Table
  • Product Image: Product Image
  • Product Description:

    Ronald Hirsch, MD, FACP, CHCQM
    Jill Knight, RHIA, CCS, CIRCC

Uncertainty remains regarding specifics of documentation.

A couple of weeks ago I talked about the new national coverage determination (NCD) for defibrillators. At the time, the effective date was not known. Well, it is now clear: it was effective immediately. That NCD also added the requirement for a formal shared decision-making encounter using an evidence-based tool.

At the time, I questioned how we are to document such an encounter, since some of the tools are online. And the answer from the Centers for Medicare & Medicaid Services (CMS) was that they don’t know, since the claims processing instructions have not yet been written. So for now, we are left in limbo. If you use a paper tool, get a copy. If you do it electronically, note the tool used in the medical record.

Many of you may have seen an article published Friday by USA Today and Kaiser Health News titled “As Surgery Centers Boom, Patients Are Paying with Their Lives.” In this article, data was presented on the number of patients who have died in ambulatory surgery centers, because either the equipment or personnel needed to care for a complication were not available or they were sent home prematurely.

This article is especially important now, since CMS soon will be considering allowing a wide range of services in surgery centers, including joint replacements, electrophysiology procedures such as ablations and defibrillator implants, and cardiac procedures, including cardiac catheters and stents. And if you remember my article published last year, Humana has already stated that the Medicare inpatient-only list does not apply to them, and that their Medicare Advantage beneficiaries can have inpatient-only surgery at surgery centers (that includes all joint replacements, hip fracture repair, carotid artery stents, ablations, cervical spine fusions, and many more). I am hoping that this new article gets CMS’s attention, and that they reconsider their plans and stop Humana from endangering the lives of our seniors.

Last week CMS did hold its Open Door Forum, and as expected, many questions were asked about total knee replacement. And also as expected, there were few answers. I especially want to acknowledge a Monitor Mondays listener from TriHealth in Cincinnati, Linda Hogel, who called in and really brilliantly explained the difficulties we are all facing. I continue to support my position that even if your patients go home in one midnight, they can be admitted as inpatients as long as documentation supports that they are at higher risk. Each must be assessed on a case-by-case basis. I also think that CMS is going to work with the Quality Improvement Organizations (QIOs) to be sure they understand that one-day stays are allowed if documentation supports it. But my opinion is far from universally accepted. So the best I can say is that each facility must do what they think is right.

 Listen to Dr. Hirsch every Monday on Monitor Mondays, 10 a.m. EST, click here to register.

Comment on this article

Ronald Hirsch, MD

Ronald Hirsch, MD, FACP, CHCQM-PHYADV, CHRI, FABQAURP is vice president of the Regulations and Education Group at R1 Physician Advisory Services. Dr. Hirsch’s career in medicine includes many clinical leadership roles at healthcare organizations ranging from acute-care hospitals and home health agencies to long-term care facilities and group medical practices. In addition to serving as a medical director of case management and medical necessity reviewer throughout his career, Dr. Hirsch has delivered numerous peer lectures on case management best practices and is a published author on the topic. He is a member of the Advisory Board of the American College of Physician Advisors, a member of the American Case Management Association, and a Fellow of the American College of Physicians. Dr. Hirsch is a member of the RACmonitor editorial board and is regular panelist on Monitor Mondays.

The opinions expressed are those of the author and do not necessarily reflect the views, policies, or opinions of R1 RCM, Inc. or R1 Physician Advisory Services (R1 PAS).

This email address is being protected from spambots. You need JavaScript enabled to view it.

Related Articles

  • Philip Esformes Has Sentence Commuted
    I have written four previous articles on Philip Esformes, who was sentenced to 20 years in federal prison for a truly infamous scheme to defraud Medicare out of millions of dollars. He bribed doctors and other providers of care to…
  • Credible Allegations of Fraud Yield Immediate Medicare Payment Suspension
    Credible allegations of fraud is a low standard to meet. If you are accused of Medicare fraud, your Medicare reimbursements will be immediately cut off without any due process or ability to defend yourself against the allegations. If you accept…
  • COVID Vaccines Begin Rollout as Medicare Announces Coverage
    Moderna’s vaccine is expected to be shipped to providers nationwide, on the heels of Pfizer’s. A reeling nation couldn’t have asked for a better Christmas present. The Food and Drug Administration (FDA) issued an Emergency Use Authorization (EUA) for the…