CMS Releases OPPS Final Rule for 2011
CMS' suspension of requirements for now for CAHs and rural hospitals clearly shows, it has an understanding that there are nuanced concerns specific to CAHs and rural hospitals that must be carefully addressed, says Shah.
"We should not see this as CMS backing away from wanting the same quality and safety requirements across all hospitals," Shah says. "Instead, we should view this as CMS taking an even-handed approach by listening to the operational and staffing challenges that CAHs and rural hospitals would face if forced to live under the current physician supervision requirements. I think this thoughtfulness on CMS' part is a really good sign that the agency is listening and moving forward cautiously.
Adding a services category
CMS selected 16 services to include in the new category of nonsurgical extended duration therapeutic services, including observation, intravenous infusion, subcutaneous infusion, and therapeutic, prophylactic, or diagnostic injections. When selecting the services for the new category, CMS stated the services must:
- Be of extended duration, frequently extending beyond normal business hours
- Largely consist of a significant monitoring component typically conducted by nursing or other auxiliary staff
- Be of sufficiently low risk, such that the service typically would not require direct supervision often during the service
- Not be a surgical service that includes recovery time
CMS excluded all surgical services—including recovery time—from potential inclusion because, although monitoring of any patient in recovery is a component of surgery, it is not the focus or a substantial component of the service. In addition, CMS states it believes the surgeon should personally evaluate the patient's medical status during the recovery period.
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