Corporate Compliance

Note from the instructor: CMS posts questions and answers on three-day window

Medicare Insider, July 31, 2012

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Slipping by somewhat unnoticed, CMS posted a set of Q&As on their Three-Day Window website a few weeks ago. The questions focus on the more recent guidance for freestanding entities, such as physician offices and ASCs that are wholly-owned or wholly-operated by a hospital. The questions also contain some information more broadly applicable to other service settings.

One interesting answer related to what is considered a diagnostic service. In the hospital setting, this has always been defined by diagnostic revenue code and in some instance HCPCS code. CMS had published a list of these revenue codes and HCPCS codes in Medicare Claims Processing Manual, Chapter 3 § 40.3. 

This list has a couple of problems though. First, the list has not been updated since the major change to the payment window in 2010.   This has resulted in the list containing outdated HCPCS codes that have been replaced by the CPT. Second, defining diagnostic services by revenue code is not helpful in the physician environment because their claims are submitted on a CMS 1500 and do not use revenue codes. 

Continue reading Kimberly's note at the Medicare Mentor Blog.



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