Corporate Compliance

Strategies for tackling the 2009 OPPS final rule

Medicare Insider, November 18, 2008

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By now, many of you may have started to look over the display copy of the 2009 OPPS final rule. Personally, I find the display copy somewhat hard to use because of the way it is formatted (i.e., triple line spacing, etc.). At 1,827 pages, printing the display copy produces a huge volume of paper, even when printed double sided.

The good news is that the “official” Federal Register copy is scheduled for publication in today’s (November 18) Federal Register. To access today’s Federal Register, visit http://www.gpoaccess.gov/fr/index.html and click on one of the links embedded in “Browse the Table of Contents from today's issue in HTML or PDF formats.” The official copy should be less than half the size of the display copy due to differences in formatting between the two versions.

A good way to tackle the final rule is to start by browsing the table of contents to get a feel for the big picture. After reviewing the table of contents, I usually read the new and revised regulations, which appear at the end of the “preamble.” The preamble is CMS’ detailed discussion of the rule, including CMS’ response to comments on the proposed rule submitted by the public. To quickly access the regulations section of the final rule, search for the text “List of Subjects.” After I’ve reviewed the new and revised regulations, I then go back and read the preamble (or at least the sections of the preamble that are relevant to my work). Although the preamble is merely interpretative guidance (rather than law), it typically provides a treasure trove of important details relating to hospital compliance and revenue cycle management.



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