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The Useful 5: Regulatory Roundup for Rev Cycle Leaders

Analysis  |  By Amanda Norris  
   February 02, 2023

HealthLeaders' regulatory round up series highlights five essential governing updates that cover every aspect of the revenue cycle that leaders need to know. Check back in each month for more updates.

The revenue cycle is complex, detailed, and always changing, so staying on top of regulatory updates and latest best practices requires revenue cycle leaders' constant attention in this ever-changing industry.

In this revenue cycle regulatory roundup, there were an ample number of updates published by CMS and the OIG in January, including ICD-10-CM code updates and the OIG’s Work Plan.

The PHE is seeing an end.

The COVID-19 public health emergency (PHE) will end on May 11 according to a policy statement released by the Office of Management and Budget opposing House resolutions that would end the emergencies immediately if passed.

This will have implications on reimbursement for the revenue cycle, so stay tuned for future coverage.

New diagnosis codes were release, effective in April.

The CDC updated the ICD-10-CM coding guidelines and added new diagnosis codes for the April 1, 2023 quarter. Most of the coding changes apply to codes for social determinants of health, such as inadequate access to resources, threats of violence, and more.

CMS should bolster its oversight of ASP data, the OIG says.

The OIG published a review of CMS’ oversight of manufacturer-reported average sales price (ASP) data, as the data is used to help calculate Part B payments and therefore there are concerns about the impact of inaccurate data on Part B spending.

The OIG found that there were gaps in CMS’ oversight of this data, as CMS’ quality assurance procedures did not include checks to ensure the accuracy of manual processes employed to analyze the data used to calculate Part B payment amounts.

The OIG also found CMS does not leverage its data collection system to produce reports that could monitor ASP data quality and aid in oversight. Because of invalid or missing data, CMS had issues calculating ASP-based payment amounts for a small amount of drug codes, and that can often lead to higher drug payment amounts for Part B drugs.

The OIG also found that 24% of drug codes were missing ASP data for drugs within that code in at least one quarter from 2016-2020. The OIG recommends CMS determine a strategy to strengthen its internal controls for ensuring the accuracy of Part B drug payments. CMS concurred with the OIG recommendations.

CMS slid in an update to the OPPS.

CMS published Medicare Claims Processing Transmittal 11801which updated tables 5, 6, and added table 20 in the OPPS rule. This change updates the pass-through status of five devices that will now have an extended pass-through status for a one-year period beginning on January 1, 2023.

OIG updated its Work Plan.

The OIG updated its Work Plan and will be setting its sights on the following new items:


Amanda Norris is the Director of Content for HealthLeaders.

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