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8 Three-Day Rule Tips for Hospitals

James Carroll, for HealthLeaders Media, August 18, 2010
  1. Do not drastically change your methodology. Don't go back and try to change something you've already done because you can't reopen a claim, according to Malm. In addition, do not take the approach of waiting to see what the final CMS guidelines will be and continue using the regulation from before June 25th. "If something is completely unrelated, then you should continue to bill as unrelated," he says.
  1. Avoid deeming services unrelated unless a "reasonably prudent" person could come to the same conclusion, Malm continued. "For example, you have an ambulatory surgery visit on Monday for a cataract repair. On Wednesday, you are admitted for a motor vehicle accident with multiple traumas. The 'form and function' here are clearly unrelated, and a 'reasonably prudent person' would be able to make this determination."
  1. Lean on CMS guidance. If you are receiving advice that is not consistent with Medicare Claims Processing Manual and Benefits Policy Manual regulations, you more than likely are having an issue. "Consulting the rule and law itself is the prudent course of action for providers," says Malm.
  1. Keep in mind that nothing has changed for diagnostic services provided before an inpatient admission, according to Kimberly Anderwood Hoy, JD, CPC, director of Medicare and Compliance for HCPro, Inc. "However, non-diagnostic services on the day of admission and for three days before an admission will now be considered part of the admission," she says. "For services in the three days before admission, but not the same day, hospitals can demonstrate they are unrelated and continue to bill separately to Part B."
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