Health Information Management

Q&A: Why are reporting requirements changing for services in outpatient clinics?

APCs Insider, November 21, 2014

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Q: We have acquired several physician offices and the physicians work in our off-campus clinics. We have a standing meeting with them for coding discussions and they mentioned that Medicare is going to be gathering information based on the services they provide in our off-campus clinics. These are hospital outpatient departments, so why are they different than the other hospital departments and clinics that we have?
A: From a day-to-day operations perspective, they may not seem any different than your other outpatient departments. Patients come for services, receive the services, charges are entered, claims are filed, and reimbursement is received.
CMS has noticed that the number of claims they are receiving on the professional side show a site listed as “hospital outpatient,” and the payment for services provided in the outpatient hospital department is higher than that for services provided in the physician office. 
Because of this trend, CMS wants to capture information related to the services provided in off-campus, provider-based departments (OCPBD) and the effect on payments and beneficiary cost-sharing. Place of service code 22 (hospital outpatient) will be deleted sometime in 2015. For 2015, CMS is requesting two new place of service codes as replacements to identify when a service is provided in an OCPBD versus in an on-campus department. Once these new place of service codes are available, they will become mandatory on professional claims. CMS anticipates this will be sometime around July 1.
For the facility portion of the service, CMS has created new modifier -PO (services, procedures and/or surgeries provided at off-campus provider-based outpatient departments). Coders will append the modifier to every service provided in the OCPBD when reported on the UB-04. CMS recognizes that hospital providers need time to change systems, test the changes, and educate staff for appropriate modifier application. The modifier is already active, but reporting is voluntary for 2015 and CMS notes in the OPPS final rule that it “welcomes early reporting.” The modifier will be mandatory beginning January 1, 2016.
Editor’s note: Denise Williams, RN, CPC-H, seniorvice president of revenue integrity services at Health Revenue Assurance Associates, Inc., in Plantation, Florida, answered this question.

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