Return readers will be happy to hear that the CMS is delaying its changes to E&M payments. In the 2019 Medicare Physician Fee Schedule Final Rule, the CMS stated it will not be reducing E&M payments from five levels to two, but to three levels, and that it will not be doing it until 2021. Levels one and five will remain as they are, but levels two through four will be combined into one, medium, level of E&M services. The CMS states this will allow physicians to care for higher acuity patients without being financially penalized. The AHA has applauded this move, but it is interesting to think about whether they would have preferred the old, five-tier system, even more.
Social Determinants of Health
Comments by Alex Azar, head of HHS, a few weeks back turned heads when he stated that people should stay tuned to what is happening with the Center for Medicare and Medicaid Innovation. Interested in the social determinants of health, and not just what happens in the hospital, Azar has stated the administration is looking at using federal funds to pay for housing for patients. At the same time, the CMS is working on a proposed rule to let states stop paying for non-emergent medical transportation working against the improvement of patients’ social determinants of health. Medicaid patients already have a high no show rate and removing part of the incentive for healthcare organizations to help them show up will not help. I will be waiting to see if this rule actually comes forward. You should be waiting to see if your state would like to reduce your reimbursement for this service to patients.
The Trump administration is also asking for recommendations about how to change the rules related to kickbacks and payments related to influencing Medicaid and Medicare beneficiaries. Healthcare organizations are already seeing the opportunity to improve care coordination and have started lobbying. If you have an opinion about how things can be loosened up, hit up the administration.
Finally, it is time to return to the OIG Work Plan. A new focus of the OIG could have large consequences. Stating that seventeen percent of Medicare payments are for inpatient hospital stays, the OIG is investigating how inpatient billing has changed over time. Reviewing Medicare claim data, the OIG will look for upcoding and miscoding resulting in overpayments by the federal government. Ensuring accurate coding is always important, and weekly, monthly, or quarterly audits are useful for keeping track of your staff work, now HHS is getting involved to see if your organization has been billing in a manner inconsistent from your peers.
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