CMS Unveils Billing, Coding Guidance

James Carroll, October 11, 2010

CMS and the Medicare Learning Network recently released the Medicare Quarterly Provider Compliance Newsletter; the first in a series of publications intended to offer providers guidance on avoiding common Medicare billing and general errors.

The quarterly newsletter will focus on top issues identified through various sources in each edition, according to CMS. While some of the information presented in the newsletter is an overview of existing guidance, there were a handful of items that providers should note, according to Kimberly Anderwood Hoy, JD, CPC, director of Medicare and Compliance for HCPro, Inc.

Hoy says that there is some ambiguity when it comes to certain guidance.

Under the recommendations for inpatient hospital services—respirator system diagnosis with ventilator support: principal diagnosis on the claim did not match the principal diagnosis in the medical record.

CMS provides guidance instructing the provider to consult the Benefit Policy Manual, Chapter 15, Section 50.2, on self-administered drugs, which is not applicable to inpatient hospital services, says Hoy.

"It's not clear whether or not they are suggesting that there were a lot of self-administered drugs in the outpatient environment prior to the inpatient admission being billed on the claims in error."

CMS also provides some indistinct education on the issue of unnecessary inpatient services or inpatient services in the wrong setting. 

"In regard to the medical necessity of inpatient pacemaker cases, they indirectly draw attention to condition code 44 by referencing the coinciding transmittal, which suggests that CMS is saying hospitals should be monitoring pacemakers sooner so that they can apply condition code 44 to these cases," she says.

James Carroll James Carroll is associate editor for the HCPro Revenue Cycle Institute.
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