The Centers for Medicare & Medicaid Services (CMS) released the 2022 Outpatient Prospective Payment System (OPPS)/Ambulatory Surgery Center (ASC) Payment System final rule (OPPS Final Rule), finalizing several policies proposed, including provisions of the Hospital Price Transparency, substantially increasing financial penalties for non-compliance.

​A full year of non-compliance with the price transparency regulation can potentially result in a maximum penalty of about $2 million per hospital.

CMS is modifying the approach for presenting the new technology add-on payment (NTAP) related ICD-10-PCS procedure code requests that involve the administration of a therapeutic agent for the March 9-10, 2021 ICD-10 Coordination and Maintenance Committee meeting.

​CMS is soliciting public comments in advance of the meeting. Be sure not to miss your opportunity to participate. 

Since the beginning of the pandemic, there have been many code changes and updates related to COVID-19 (SARS-CoV-2), with even more for 2021, including new ICD-10-CM diagnosis codes implemented on January 1, 2021. Among these is code Z20.822, contact with and (suspected) exposure to COVID-19, which previously required the code Z20.828.  Pay attention to the specific dates around Z20.822 and Z20.828, as this will be critical for billing. 

There has been some confusion around updates related to the Glasgow Coma Scale (GCS) codes. Changes affecting GCS, though not clearly explicit but certainly significant, were made in the recent updates to the FY2021 ICD-10-CM Official Guidelines for Coding and Reporting.  

With multiple accounts of a lack of clarity around these changes, there have been discussions of additional specific guidance to be offered in the future, though no specifics given. ​Essentially, the revised guideline is designed to prohibit GCS reporting in non-trauma. 

The federally declared public health emergency (PHE), set to expire on October 23, was renewed and will remain due to the continued impact of the COVID-19 pandemic. The more relaxed regulatory rules regarding Medicare and Medicaid compliance associated with the PHE is no more, as healthcare provider’s ramp up preparedness with focus on internal processes. 

​In the early stages of the pandemic, CMS guidance indicated that a provider's documentation was sufficient to receive reimbursement from payers. The 20‐percent higher Medicare reimbursement for inpatient COVID treatment and a positive test result was not necessary. However, effective September 1, 2020, CMS has enlisted a mandate requiring hospitals to have positive COVID‐19 laboratory tests in patients' records to qualify for Medicare's 20‐percent add‐on payment. Suffice it to say, ensuring appropriate reimbursement for COVID-19 claims require careful management and attention to detail. 

Though the response has been swift, when the virus first emerged, there were no specific codes or guidelines set and no process to document testing accurately. We now have designated diagnoses codes and guidelines for COVID-19, but bringing coding teams up to speed will require diligence. The COVID-19 billing considerations are even more complex.

Recently, congress passed the Coronavirus Aid, Relief, and Economic Security (CARES) Act, which provides more than $100 billion in direct aid to hospitals and other providers. This includes a 20 percent increase in reimbursement for inpatient COVID-19 claims.  

April welcomes the anticipation of spring and its promise of renewal. It is also the month for us to recognize the importance of our ability to volunteer and give back to our communities. However, this year the volunteer landscape is quite different than years past. The current environment can leave one asking the question ─ What can one do at a local or global level when in isolation?