Corporate Compliance

Busy week: OIG Work Plan, CMS' MUE list available

Medicare Insider, October 7, 2008

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There were a number of significant regulatory developments last week, including the release of the payment rate data and implementing instructions for the 2009 inpatient prospective payment system (which went into effect last week) and the release of the OIG’s 2009 Work Plan. Perhaps the most interested development; however, was CMS’ publication of most, but not all, of the Medically Unlikely Edits (MUE). As of last week, CMS had published on its Web site 5,834 MUEs. It is unclear how many MUEs CMS is still keeping confidential. However, CMS has indicated that the 5,834 edits published last week are “most” of the MUEs.

Although the MUE program has been in place for several years, prior to last week, CMS had kept the actual edits confidential. This has always been frustrating for providers because it made it difficult to implement internal unit-of-service edits. However, prior to last week, CMS seemed to believe that releasing the edits might result in providers gaming the system.

Now that some of the MUEs have been published, hospitals should work with their system vendors to have the published edits added to their claims scrubber software as soon as possible. Also, hospitals should review the edits and fax a “request for reconsideration” to Correct Coding Solutions, LLC, at 317/571-1745, if any of the edits seem inappropriate. Correct Coding Solutions, LLC, is the organization with which CMS has contracted to develop and maintain the National Correct Coding Initiative (NCCI) edits and the MUEs. It may also be helpful to work through the medical specialty societies (e.g., American College of Radiology) in attempting to get Correct Coding Solutions, LLC, to revise particular edits. In the past, Correct Coding Solutions, LLC, has been responsive to requests for reconsideration relating to the NCCI edits. Presumably, they would also be responsive to requests for reconsideration relating to the MUEs.



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