Corporate Compliance

Note from Hugh

Medicare Insider, January 8, 2008

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I have three issues I'd like to discuss this week. First, as noted below, CMS has now released the first quarter 2008 Outpatient Code Editor (OCE) specifications. Everyone should study the transmittal (and the associated MLN Matters article) carefully as the 2008 OPPS final rule necessitated a number of significant changes to the OCE specifications.  Many of the changes relate to CMS replacing separately payable observation services with the new "Extended Assessment and Management" composite APCs. Also, CMS has added a new OCE edit (Edit 78) titled "claim lacks required radiopharmaceutical." Hospitals will want to make sure that they implement a parallel edit in their internal claims scrubbers for dates of service after January 1, 2008.

Second, in a previous issue of Medicare Weekly Update, I discussed my concern that many of the CMS frequently asked questions (FAQs) that are listed as "updated" on the CMS web site ( do not appear to have been changed.  I sent CMS an e-mail concerning this issue and recently received the following response:

    "No matter what is done to an FAQ (extend expiration date, correct spelling of a word, change name of SME, etc) the system automatically sees it as being updated and notes it as so. We have no control over that. In essence, anything we do to an FAQ, even the smallest thing causes it to be removed from the database and placed back in, causing the new status to say update." 

I sent a follow-up e-mail to CMS asking if it would be possible to embed a "manual" revision date in the text of the answer. I think that would solve the problem. I'll report back on any response I receive from CMS.

Finally, we recently received the following question from a reader:

    "I have heard recently from other facilities that as of January 1 2008 facilities can no longer charge out consultation codes. Have you seen or heard anything about this issue?"

The reader is correct. Effective January 1, 2008, CMS changed the status indicator of the outpatient consultations codes (CPT codes 99241 through 99245) to "B," which means the codes are not recognized for payment under the OPPS. On p. 217 of the 2008 OPPS final rule, CMS explained that "[a]s appropriate, hospitals could build consultation services into their internal hospital guidelines related to reporting clinic visit levels, based on the complexity and resources used for these visits."

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