Corporate Compliance

Note: Updates on three day payment window and supervision at CAH hospitals

Medicare Insider, April 13, 2010

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Editor’s note: Kimberly Hoy, Esq., director of Medicare and compliance for HCPro, Inc., is the author of this week’s note from the instructor. Hoy is a speaker at HCPro’s Medicare Compliance Forum, May 6-7, in Las Vegas. Learn more about the Medicare Compliance Forum.

This week there wasn’t a lot of new information from CMS so I thought I would update you on a couple of the issues we have recently reported on in Medicare Weekly Update.

The first is the three-day rule, which we reviewed last month following a Hospital Open Door Forum call in which Marc Hartstein, Deputy Director of CMS’ Hospital and Ambulatory Policy Group, reiterated the requirements for therapeutic services provided in the three days before an inpatient admission.  He emphasized that the hospital may not bill “unrelated” outpatient services provided in this timeframe on the subsequent inpatient claim, although he did say it was the hospital’s option to bill these separately as outpatient services.  As we have discussed, “related” is defined by CMS in this context to be an exact match of the principal ICD-9 diagnosis code for the inpatient stay and the outpatient service.

Continue reading Kimberly's note at the MedicareMentor Blog.



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