Corporate Compliance

Note from Hugh

Medicare Insider, July 3, 2007

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A couple of weeks ago Bob Rogalski and I presented an HCPro audioconference on Medicare's three-day payment window. After the audioconference, several participants commented on the confusion surrounding the impact on an inpatient claim of "moving" onto the claim charges for a surgical procedure performed prior to the inpatient admision but subject to the three-day payment window. The fundamental question was whether the surgical "charge" could affect DRG assignment (and therefore payment) for the inpatient claim.

As several participants pointed out after the audioconference, it appears that the surgical procedure could affect DRG assignment even though the surgical procedure was performed prior to the inpatient admission. In the 1998 final rule on the three-day payment window, CMS stated:

When services are furnished within the three-day payment window, they are included on the Part A bill, the HCFA-1450 (also known as the UB-92), for the inpatient stay.... The charges, revenue codes, and ICD-9-CM diagnosis and procedure codes are all included on the HCFA-1450. [63 Fed. Reg. 6866 (emphasis added)]

Although not entirely clear, CMS appears to take the position (at least in 1998) that an ICD-9-CM procedure code should be assigned for a preadmission surgical procedure and included on the inpatient claim in addition to the charge for the surgical procedure. As always, however, hospitals should confirm this with their local FI or MAC, especially given that the CMS guidance on this issue is almost 10 years old. In some cases, the inclusion of an ICD-9-CM procedure code for a preadmission surgical services could affect the DRG assignment for the inpatient claim.

On an unrelated note, everyone should have now received the dial-in information for next week's CMS Hospital Open Door Formum conference call. If you missed it, here it is:

Date: July 12, 2007
Start Time: 2:00 PM Eastern Daylight Time
Dial: 800/837-1935
Conference ID: 2467196

Registration is not required.

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