This allows the hospital the ability to bill for Part B service when the facility has determined the stay did not meet medical necessity criteria or could apply when the patient did not stay two midnights and the documentation is not strong enough to support the short stay.
The patient will also be responsible for outpatient coinsurance, deductible, and out-of-pocket expense, even for services that occurred prior to the inpatient order being written because the three-day payment window will not apply for PPS hospitals, Mackaman says. CMS also stated in the final rule that the decision by a hospital to not bill the patient for their portion of the outpatient services may implicate other regulations and that hospitals should contact the OIG for more guidance.
Documentation and coding adjustment
The American Taxpayer Relief Act of 2012 requires CMS to recover $11 billion over the next four years to fully recoup documentation and coding overpayments for prior years. For 2014, CMS will apply a negative 0.8% recoupment adjustment in FY 2014.
"The documentation and coding reduction will need attention of hospital leaders, especially HIM, coding and CDI," says Gloryanne Bryant, RHIA, CCS, CDIP, CCDS, an HIM coding professional and advocate with more than 30 years of experience. "With ICD-10 efforts underway further awareness and collaboration with physicians will be needed. Reenforce documentation concepts. Now is the time to establish a physician champion or liaison for documentation and coding." Bryant also recommends conducting an audit to identify areas for improvement now even if you have a CDI program in place.
The final IPPS/LTCH PPS rule can be downloaded from the Federal Register.