On the other hand, these new instructions may provide some financial relief for facilities receiving Part A stay denials, says Valerie A. Rinkle, MPA, vice president of Revenue Integrity Informatics with HRAA, in Plantation, FL.
"CMS has provided needed relief with this ruling and proposed rule, which allows hospitals to receive legitimate Part B payment for medically necessary services provided to patients during a Part A stay found post discharge to not meet the narrow medical necessity requirements for Part A coverage," she says.
"Hospitals will need to make a decision after each Medicare contractor (RAC or MAC) denial of a Part A stay to either appeal or accept the denial and rebill under these new instructions."
It is important for providers to be aware of the fact that CMS is soliciting comments on the patient liability issues their instructions create. Providers should take particular notice of the issues around non-covered self-administered drugs and the fact that the Part B liability could exceed the patient's original Part A deductible liability, says Rinkle.
"I encourage hospitals to provide comment to CMS on any ideas to limit patient liability and exposure because we all know this is often a patient and public relations concern," she says.
View the notice of ruling.
View the proposed rule.
Submit comments on Regulations.gov.