Corporate Compliance

Note from Hugh

Medicare Weekly Update, April 2, 2007

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This week we didn't see a lot published from CMS for the hospital industry. I would suspect they are occupied with the Inpatient Prospective Payment System proposed rules for fiscal year 2008 which should be on display on their Web site within the next few weeks. It will be interesting to see if CMS moves forward with their plan to transition to the CS-DRG system (based on APR-DRG system by 3M) for fiscal year 2008.

You might find the question and answer covered under the "Other CMS Developments" section interesting. CMS stated that the new Medicare Administrative Contractors (MACs) will use the least restrictive Local Coverage Decisions (LCDs) from throughout their jurisdiction when taking over operations from the current fiscal intermediaries. This appears to mean that in cases where there is an LCD in just one state of the jurisdiction, it would begin applying to all states in the jurisdiction as the "least restrictive" when the MAC begins operations. Additionally, although the MACs will initially use the "least restrictive" LCDs, hospitals should anticipate that they may publish more restrictive draft LCDs for comment and adoption. Upon coming under the jurisdiction of a MAC, hospitals should watch closely for new draft LCDs and put in comments as necessary to ensure their current practice is taken into account in the decision making process.

~ Kimberly Anderwood Hoy, Esq.

Editor's Note: Kimberly Anderwood Hoy, director of Medicare and compliance for HCPro, Inc., is the author of this week's "Note from Hugh" in Mr. Aaron's absence.



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