Corporate Compliance

Note from Hugh

Medicare Weekly Update, July 24, 2007

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As noted below, CMS has released the display copy of the 2008 OPPS proposed rule. HCPro's editorial staff has prepared a three page summary of the proposed rule. The summary includes some interesting comments on CMS' proposed OPPS changes from Jugna Shah, MPH, president of Nimitt Consulting. Click here to access a free copy of the summary.

The proposed rule also includes a number of proposed changes that do not have anything to do with OPPS. Theses include changes relating to:

  • Medicare's Ambulatory Surgery Center payment system
  • The Conditions of Participation requirements relating to documentation of history and physical exams for outpatients
  • Restrictions on the ability of Critical Access Hospitals to create or acquire "off-site locations"

As also noted below, CMS issued another transmittal last week relating to reporting of present on admission (POA) indicators. Interestingly, this new transmittal is virtually identical to the POA transmittal issued in May, except that the new transmittal states in the "Summary of Changes" section that hospitals must begin reporting POA indicators beginning October 1, 2007. I discussed the latest transmittal with Pat Brooks at CMS. Ms. Brooks informed me that she does not believe that CMS intended to make any substantive changes in the latest POA transmittal. She also noted that the effective date of the latest transmittal is January 1, 2007. According to Ms. Brooks, POA reporting will not be mandatory until January 1. However, she was not able to explain why the latest transmittal stated that POA indicator reporting will be required beginning October 1. Given this inconsistency between the date listed in the "Summary of Changes" section of the transmittal and the transmittal's stated effective date, hospitals may want to check with their local FI or MAC for guidance as to when they must start reporting POA indicators.



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