what did CMS take a giant step toward applying in the CMS 2012 proposed Medicare physician fee update?
applying the DRG payment window policy to hospital owned physician practices
When will this extension of the drg window be implemented?
Jan 1, 2011
into what, under medicare's DRG window payment policy, must all out patient DX services be bundled (the same applies to non dx svcs if they are related to the admission)?
all outpatient services must be bundled into the MS-DRG when they are provided up to three days before admission
What sort of clinics already live by the the DRG window payment?
How is CMS connecting the last dot here?
by extending the DRG window payment rule into hospital owned, non provider based, entities
What, in effect, would this extension analogously be in the way CMS views the hospital practice relationship
CMS is now effectively viewing the practice as an outpatient department of a hospital and pay physicians a lower fee for pre-admission services
By CMS viewing the practice as an outpatient dept of the hospital under this extension, what impact does this have on charges and what is CMS's associated rationale for that?
(1) physician fees for pre-admission services would drop (2) this is because CMS believes hospital picks up the tab for office expenses
How specifically are the terms by whioch Medicare would make payments under the extension?
Medicare would make payments under the physician fee schedule for the physician services that are subject to the 3 day payment window at the facility rate
What will the payment window apply to according to CMS
Payment window will apply to all DX services furnished and to any non DX services that are clinically related to the reason for the patient's inpatient admission
What if the ICD 9 CM DX codes are the same for the inpatient and outpatient?
the paynment window will apply to all dx and non dx clinically related to the patient's in service regardless
How would professional vs technical components be billed under the xtension?
Medicare will only pay professional compnent....
How would professional vs technical components be billed under the xtension if there is no technical professiopal split? What is the rationale here?
if no technical/professional split, CMS will pay the facility rate for the preadmission service...the rational is to avoid any duplicate reimbursemnt for for technical resources that will be charges by the hospital and included in the hospitals inpatient claim for the related patient admnission.
How will, technically, charges be billed by the practice?
CMS is creating a HCPS modifier that's necessary to carry out the DRG payment window change...Hospital owned practices would be required to append the modifier to physician preadmission services subject to the 3 day payment window
Why is the proposal rational?
it makes sense because a hospital owned free standing clinic only bills professional services. The hospital owns the entity and pays it's overhead, but medicare is already reimbursing the physician for it through their professional fees. By bundling hospital charges and paying the facility rate, CMS eliminates this redundancy.