CMS Clarifies IPPS Rule on Services Made 'Under Arrangement'

“While this isn’t a huge change, it’s definitely something of which providers should be aware. If you look at the example of CSW services provided during inpatient stays—which is an approved issue for all four recovery audit contractors (RACs)—this clarification could have implications for how this is billed if the ‘in hospital’ exception is not extend broadly to all contracted services, leaving these unbillable by both the hospital and the CSW,” Hoy says.

Since this clarification was in the IPPS proposed rule, providers—particularly those that provide inpatient services outside of the hospital—will want to keep an eye out for the final rule later this year. In addition, affected providers should submit comments on this rule if they have questions or concerns about how this will affect contracted medical social services or other services they provide, Hoy says.