The Centers for Medicare & Medicaid Services held its first Hospital Outpatient Payment Panel meetings this year and has issued proposals on the changes to current supervision levels for the following categories:
- Influenza, pneumococcal, and hepatitis B vaccine administration
- Trimming of nails
- Venipuncture via vein, VAD, or central catheter
- Foley catheter insertion
- Changing of cystostomy tube
- Bladder scan for residual urine measurement
- Refilling portable pump
- Irrigation of implanted VAD
- IV hydration, initial hour and each additional hour
The last item, IV hydration, had been previously identified by CMS as a "non-surgical extended duration service," in the CY 2011 OPPS final rule. These types of services must be provided under direct supervision during the initiation of the service, followed by general supervision for the remainder of the service, says Debbie Mackaman, RHIA, CHCO, regulatory specialist for HCPro, Inc.
Initiation of this service is defined as the beginning portion of the service until the supervising physician or non-physician practitioner determines the patient is stable and the remainder of the service can be delivered safely under general supervision, she adds.
The supervising physician must document the transition from direct to general supervision in the patient's medical record.
CMS also detailed the services for which CMS did not accept the panel's recommendations that they be furnished under general supervision.
These services were denied because they either involve assessment by a physician or include a significant potential for patient complications or reactions that would require the supervising physician or appropriate non-physician practitioner to be immediately available, explains Mackaman. These services are:
- IV infusions and injections that are currently designated as non-surgical extended duration services
- H1N1 vaccine administration with family counseling
- Bladder irrigation
- Two casting/strapping procedures
- Direct admission for observation and observation per hour
"CMS announced in the 2013 OPPS proposed rule that they are considering giving critical access hospitals and small rural hospitals one more year of non-enforcement for meeting supervision rules and also stated that it would most likely be the last year for that waiver," Mackaman said.
"Based on CMS' position that there is a significant potential for patient complications in regards to observations services, it is highly unlikely that we will see this move to a general supervision category any time soon, so CAHs and the small rural hospitals should begin to prepare now."
This was the first year that CMS asked representatives from CAHs to sit on the panel to help make these recommendations on supervision requirements for certain services.
"Safe quality care is an expectation that CMS has for all hospitals, regardless of how they are paid – cost vs. prospective payment," Mackaman said.
These recommendations are open for public comment through October 24 and the final decisions will become effective on January 1, 2013. Hospitals that may have a stake in loosening the supervision requirements for the delivery of these outpatient services may submit their comments via email to: HOPSupervisionComments@cms.hhs.gov.
View the most recent recommendations from the panel.
View the previous recommendations from the panel.
James Carroll is associate editor for the HCPro Revenue Cycle Institute.