*EMTALA and dedicated emergency departments
*Influenza and pneumonia vaccine standing orders

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The OIG Work Plan for Fiscal Year 2003

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Compliance Hot Topics: Billing and Coding, EMTALA, Stark, HIPAA

Question of the Week

Welcome to Compliance Monitor Q&A.

Our mission is to answer your difficult compliance questions—and your simple ones, too. To submit a question, send it to Compliance Monitor Q & A editor Kate Alvarez at kalvarez@hcpro.com. We hope you enjoy this service and we welcome your feedback.

This week's questions

• EMTALA and dedicated emergency departments
• Influenza and pneumonia vaccine standing orders

• Pay-Per-View article: Six easy steps for tackling EMTALA changes

• How does your organization handle patient financial issues?

Q: Our reader asks, "Our hospital owns a rural health clinic located on the same campus as the hospital. The clinic is not advertised as 'urgent care,' but by virtue of the fact that it accepts walk-in patients from 10 a.m. until 8 p.m., we do provide care on an urgent basis. Does the dedicated emergency department definition apply to the clinic?"

A: On September 3, 2003, the Centers for Medicare and Medicaid Services (CMS) issued final regulations clarifying hospital responsibilities under the Emergency Medical Treatment and Active Labor Act (EMTALA), to take effect November 10, 2003.

The final rule defines and clarifies which areas of the hospital, in addition to the traditional emergency department, are covered under EMTALA because they are considered "dedicated emergency departments." One of the requirements for being considered a dedicated emergency department is holding your facility out to the public as accepting patients in need of care for emergency conditions without requiring a scheduled appointment.

From the CMS point of view, it may be difficult for an individual in need of emergency care to distinguish between a hospital department that provides care for an urgent need and one that provides care for an emergency medical condition. Your urgent care clinic may meet the definition of a dedicated emergency department based on the public's inability to discern a difference between urgent care and care for emergency medical conditions.

This question was answered by Norman S. Werner, CHE, Associate Corporate Compliance Officer, Westchester Medical Center, Valhalla, New York.

Ever wonder how Norman Werner started answering questions for Compliance Monitor Q&A? Well, you too can help your peers with their compliance issues! Just Click here or see the information below.

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WE NEED YOUR EXPERTISE!

Join the Compliance Monitor Team! Compliance Monitor Q&A relies upon experts just like you to answer pressing compliance questions. We're looking for experts in coding, billing, documentation, HIPAA, EMTALA, Stark, laboratories, and many other areas of compliance.

If you are interested in answering questions from your peers, please e-mail Compliance Monitor editor Kate Alvarez.

Take two!

Hours that is, and join us for the audioconference that will get you ready to face 2004 with confidence. We're changing our usual format for "APC Task Force: How to Implement the 2004 Final OPPS Rule" and running it as a two-hour program. There is so much important information to share, and you'll probably have questions. We want to help you to start the new year off right!

We'll look for you on Tuesday, December 9 beginning at 1 p.m. Eastern. Bring your lunch, a pad of paper, the materials package we'll send, along with your questions.

To register or to learn more, CLICK HERE or call our Customer Service Team at 800-650-6787. Please mention source code EZ23521B when you call.

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Click here to take our quick survey on your financial policies and procedures.

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To find out more on the EMTALA changes, order the pay-per-view article EMTALA: Six easy steps for tackling the rule's changes." The cost is $10. Subscribers to the online version of Strategies for Health Care Compliance have free access to this article. Subscribers to the print edition can find it in their October issues.

A $30 steal.
You can read this article and much more in the November issue of Strategies for Health Care Compliance. Your cost: Five stories for only $30. You'll also learn about the OIG's 2004 Work Plan and how to prioritize your compliance efforts for the upcoming year, how to respond to a potential EMTALA violation, how the electronic claims rule implicates privacy and security, and why the next step in credentialing is medical staff office compliance.

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2004 OPPS and HCPCS Changes: Update Your Charge Master

Major changes to OPPS and HCPCS codes are expected for 2004! Update your charge master for accurate and maximum reimbursement. Also avoid overbilling mistakes and investigations from the OIG.

Get FREE TRIALS AND DEMONSTRATIONS on easy-to-use charge master products and services from Chargemasters.com, Holliday & Associates, and HCPro. For more information, just click here.

To sign up for FREE trials or demonstrations, click here.

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A: To read the answer to this question, click here.

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To submit your answer, go to the Question of the Week at Complianceinfo.com.

Here are the answers to the last survey:

When will your organization begin auditing its HIPAA compliance program?

• Within the next six months: 68%
• In 7 to 12 months: 17%
• In 12+ months: 9%
• We do not plan to audit: 6%

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Network with your audit colleagues

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Send your comments and questions about Compliance Monitor Q&A to:

Kate Alvarez
Editorial Assistant
kalvarez@hcpro.com