Corporate Compliance

*Charging for treatment rooms
*HIPAA-compliant electronic transactions

Compliance Monitor, December 22, 2003

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On Complianceinfo.com

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The OIG Work Plan for Fiscal Year 2003

Ask the Expert

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

Pay-per-view article
Quick survey
Questions and Answers

Charging for treatment rooms

Q: "When is it appropriate to charge a treatment room? The revenue code would be 761. For example, a physician sends a patient to the emergency room (ER) for a rabies shot. Would it be appropriate to charge a treatment room revenue code 761 and CPT code 99211? The patient is not seen by an ER physician."

A: Revenue code 761 for a treatment room should typically be billed with a procedure code reflecting the treatment, not with an E/M code. In addition, it is not appropriate to use an E/M code unless an assessment/work-up of the patient's sign/symptoms occurs. Because the CPT codes for the rabies vaccine (90675) and the immunization administration (90471) are considered "incident to" services, they must be billed with an E/M code (under Medicare) or the claim will be denied.

The following are two options to have these claims paid:

  • Indicate to the physician that the patient will have to pay for the immunization because it is considered an "incident to" service and therefore not covered by Medicare.

  • Determine how often this issue occurs. If it is recurring, consider developing an internal protocol to assess this patient before and after the administration of the vaccine, document the assessment appropriately, and charge a low-level E/M visit along with the vaccine and the immunization administration.

    This question answered by Sheryl Spohn, RHIA, a coding consultant with Pershing Yoakley & Associates in Atlanta, as published in the August issue of Briefings on Coding Compliance Strategies.

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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.


    Explanations, case studies, and practical strategies for EMTALA compliance

    "A Practical Guide to EMTALA Compliance" is a 150-page book that summarizes, clarifies, and explains EMTALA in plain-English. A study of EMTALA violations from 1996 to 2000 revealed that 90% of violations dealt with the screening, stabilization, or transfer provisions--requirements that still exist under the new law.

    This practical resource thoroughly explains these requirements, provides case studies to illustrate compliance, and gives you practical strategies to make sure you comply in every patient case!

    To order or learn more, including how you can save 10%, click here or call 800/650-6787 and mention source code EB23384D.

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    Tell us about your financial policies.

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

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    Pay-per-view article: OPPS 2004 final rule puts financial squeeze on rural hospitals

    If you are operating a rural hospital with 100 or fewer beds, get ready for a tough year. The 2004 OPPS final rule puts the squeeze on the little guys by moving forward with the forecasted elimination of the transitional corridor payments. All hospitals that qualified for receiving corridor payments over the last three years will lose this cushion, but smaller hospitals and teaching hospitals could be the hardest hit.

    To find out more about how the final rule could affect your facility, order the pay-per-view article " OPPS 2004 final rule puts financial squeeze on rural hospitals." The cost is $10. Subscribers to the online version of Briefings on APCs have free access to this article. Subscribers to the print edition can find it in their December issues.

    A $30 steal.
    You can read this article and much more in the December issue of Briefings on APCs. Your cost: Five stories for only $30. You'll also learn how to deal with the deletion of Q0085, what feedback the provider Roundtable gave CMS and what results they got in return, how to determine the codes for venipuncture, and why the final rule isn't as hard to live with as we thought it would be.

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    Medicare reform: Get the inside scoop from key Senate negotiator

    Join HCPro on Thursday, January 15, 2004, for the 90-minute live audioconference, "Medicare Reform Act: What You Need to Know to Survive and Thrive." Colin Roskey, the former health policy advisor and counsel to the Senate Finance Committee, will present his insights from his experiences inside the conference committee--and then address questions, helping hospitals implement the key reimbursement provisions, identify compliance obstacles, and understand the true intent behind the provisions in the new Medicare law.

    Click here to register or learn more. Or, call 800/650-6787 and mention source code EZ24615B.

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    HIPAA-compliant electronic transactions


    Q: "The HIPAA transactions and code sets regulations require electronic transmission of HIPAA-compliant electronic transactions to Medicare. Do the regulations require that state Medicaid transactions also be electronic and HIPAA-compliant?"

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

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    Quick survey: Does your organization train employees on Medicaid compliance issues?

    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

    "Audit Talk" is a new, moderated chat forum that members can use to post messages or questions for their peers 24-hours-a-day. "Audit Talk" offers a free forum to network, share ideas, and solve problems for those in the audit industry. Getting involved is easy. To subscribe, just send your request to this e-mail: owner-audit_talk@hcpro.com.

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    Share the news

    You've been benefiting from our informative e-mail newsletter, so why not pass on this resource to your peers? Sign up a colleague and get $20 off your next purchase on HCPro's Healthcare Marketplace!

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

    Kate Alvarez
    Editorial Assistant
    kalvarez@hcpro.com



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    DISCLAIMER Advice given is general, and readers should consult professional counsel for specific legal, ethical, or clinical questions. Users of this service should consult attorneys who are familiar with federal and state health laws.



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