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CMS Clarifies IPPS Rule on Services Made 'Under Arrangement'

James Carroll, for HealthLeaders Media, June 22, 2011

Editor’s note: This article is the third in a series of three IPPS-related updates. The first article on the three-day payment window clarification can be found here and the second article on replacement devices can be found here.

Within the inpatient prospective payment system (IPPS) proposed rule are an assortment of major and minor clarifications which—to a varying degree—will have an effect on a number of hospital departments. One of these updates comes in the form of a clarification to Medicare’s “under arrangement” provision.

When a patient is at a PPS hospital, the hospital is required to provide all covered services the patient needs. In some cases, however, the patient may require a service that the hospital cannot provide. For example, the patient may require a positron emission tomography scan and the hospital does not have a PET scanner.

The hospital may send the patient to a nearby hospital or facility for this service, but keep the patient as their inpatient throughout the process. This scenario is a perfect example of “under arrangement” services, according to Kimberly Anderwood Hoy, JD, CPC,director of Medicare and compliance for HCPro, Inc.

In the most recent IPPS proposed rule, the Centers for Medicare & Medicaid Services clarified that diagnostic and therapeutic services may be provided “under arrangement with another provider, but routine services such as nursing and medical social services must be provided by the hospital, according to Hoy.

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