- Understand that the new rule may require a look at the clinical situation of the patient, according to Hoy. "Depending on the final discussion of the standard of 'unrelated,' outpatient services may need to be reviewed by a person with a clinical background prior to being billed separately, rather than being done by a coder or compared by the billing system of matching diagnoses."
- Adjust billing practice for services provided since June 25, 2010. This should be done to ensure non-diagnostic services on the day of the admission are not billed separately, according to Hoy. "In addition, hospitals should develop a process to review services in the three days before for clinical-relatedness and documentation of services that are unrelated to support separate billing."
- Voice your opinion. "As always, I encourage everyone to comment (by September 28, 2010) to CMS with any questions and concerns they have," says Hoy. The address and instructions are at the beginning of the 2011 final rule.
James Carroll is associate editor for the HCPro Revenue Cycle Institute