Corporate Compliance

CMS issues next wave of supervision decisions on Hospital Outpatient Payment Panel

Medicare Update for CAHs, October 17, 2012

Earlier this year, CMS held its first Hospital Outpatient Payment Panel meeting, which managed to slip under the radar for some. The panel—which meets to recommend the appropriate levels of supervision for individual hospital outpatient therapeutic services—met again recently, and on September 24, details of the meeting were released.

Following the first meeting of the year, which was held in March, CMS approved recommendations that became effective on July 1, 2012. This time, the panel met in August and CMS has issued proposals on the following changes to the current supervision levels for the following categories:

  • Influenza, pneumococcal and hepatitis B vaccine administration;
  • Trimming of nails;
  • Venipuncture via vein, VAD or central catheter;
  •  Foley catheter insertion;
  • Changing of cystostomy tube;
  • Bladder scan for residual urine measurement;
  • Refilling portable pump;
  • Irrigation of implanted VAD; and,
  •  V hydration, initial hour and each additional hour.

The last item, IV hydration, had been previously identified by CMS as a “non-surgical extended duration service,” in the CY 2011 OPPS final rule. These types of services must be provided under direct supervision during the initiation of the service, followed by general supervision for the remainder of the service, says Debbie Mackaman, RHIA, CHCO, regulatory specialist for HCPro, Inc.; who also explains that initiation of this service is defined as the beginning portion of the service until the supervising physician or non-physician practitioner determines the patient is stable and the remainder of the service can be delivered safely under general supervision. The supervising physician must document the transition from direct to general supervision in the patient’s medical record.

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