Presentation on theme: "Observation Medicare and Medicaid The Ins and Outs of Coding and Billing June 2, 2014 Jean C. Russell, MS, RHIT 518-369-4986 email@example.com."— Presentation transcript:
1Observation Medicare and Medicaid The Ins and Outs of Coding and Billing June 2, 2014Jean C. Russell, MS, RHIT
2Agenda Background NY Medicaid Observation Medicare – IPPS 2014 Final RuleRebilling Denied Part A as Part BMedicare – Current Billing Requirements for ObservationMedicare – OPPS 2014 ChangesQuestions / DiscussionObservation – The ins and outs of billing and coding for ObservationIt has become increasingly difficult to follow the latest regulatory requirements for billing NY Medicaid and Medicare appropriately for observation services from both an outpatient and inpatient coding perspective. This presentation will summarize the latest requirements, what services can and should be coded and billed as outpatient observation, and how these services are reimbursed. Recent regulatory changes impacting observation will be included, as well as proposed changes that will impact observation billing in the future. In addition, we will summarize how and when a Part A Medicare inpatient claim can be billed to Part B.Program Objectives:Go over the latest Medicare OPPS and Inpatient Observation ChangesIdentify the changes to admission status determinations under Medicare IPPSLean how Medicare OPPS has changed Observation reporting and reimbursementProvide information on how to rebill a Part A denied claim as Part BUnderstand the latest NY Medicaid Observation RequirementsReview how to bill Medicaid and how Observation will be paid
4Level of Care Outpatient Status Outpatient care Observation service For example – Clinic, Emergency department, Outpatient surgery Extended surgical recovery over-nightObservation serviceMedicare Part BPaid on APCs (Medicare) and APGs (Medicaid)Inpatient StatusMedicare Part APaid on MS-DRGs (Medicare) and APR-DRGs (Medicaid)
5Medicare Observation Vs. Inpatient Stay Observation is Part B, Inpatient is Part APart A has a single deductible (co-pay) for a hospital stayPart A covers most of the cost of the stayPart B has individual co-pays for each of the procedures performed (e.g., x-rays, MRIs, ED visit, drug administrations)The cap on each individual co-pay is set at the Medicare inpatient capBut the sum of the co-pays can be significantCost to patient may well be higher as observation
6Medicare Observation Vs. Inpatient Stay Certain services covered in a Part A visit are not covered under Part BE.g., self-administered drugsServices that did not meet medical necessity (e.g., radiology)SNF coverage under Medicare requires a medically necessary 3 day admission prior to the SNF
7Observation Cases Increasing According to a recent article:The use of observation status has nearly doubled in the past six yearsObservation stays of more than 48 hours have increased from 3% to 8%Number of patients in the hospital for at least three days that could not qualify for SNF due to observation was over 600,000 last year aloneShorter stay inpatients cases are closely scrutinizedSometimes observation is a fallback to ensure the visit will be coveredSource:
8Short Stay Inpatient Admission Reviews Increasing scrutiny by private payers and auditorsTarget of Office Inspector General (OIG) and Office of Medicaid Inspector General (OMIG) audit plansFocus of Medicare’s PEPPERReviewed by Medicaid Integrity Contractors (MIC) and Medicare Recovery AuditorsReviewed by the Medicare Administrator Contractor (MAC) – NGS for New YorkAnd now subject to the Two Midnight Rule
9NY Medicaid Observation Coding, Billing and Payment 9
10NY Medicaid and Observation Effective April 1, 2011Medicaid began coverage of emergency room observation servicesHowever, the requirements for billing for the service were strict, including:Waiver requirementDistinct observation unitNY State Medicare Update, May 2011,
11April 2011 Requirements Observation Waiver Requirements: Distinct physical space (not scatter bed model)Unit can only be used for observationPatients should require 8-24 hours of careOverseen by the ERPatients must come through the ERNY State Medicare Update, May 2011,
12February 2012 ChangesEffective January 11, 2012, observation units had to be established in compliance with Title 10, Section , rather than through a waiverHospitals that previously provided services under the waiver had 24 months of the effective date of the regulation change (i.e., January 11, 2014) to be in compliance with the regulationsHealth Department Regulations Adopted for Observation Unit Operating StandardsNew York State Medicaid, including Medicaid managed care and Family Health Plus (FHPlus) plans, have reimbursed providers, effective April 1, 2011, for hospital observation services delivered in observation units. Payment has been contingent upon approval of a site-specific waiver from the Office of Health Systems Management (OHSM), Division of Certification and Surveillance.Effective January 11, 2012, Title 10 of the New York Code of Rules and Regulations, Section , was amended establishing observation unit operating standards. Accordingly, new observation units must be established in compliance with the process and standards set forth in section , rather than through a waiver. New York State Medicaid will reimburse providers for observation services in observation units that meet the new standards identified in the recently filed regulations.The regulations governing provision of observation services are available online at:New York State Medicaid will continue to reimburse hospitals for observation services delivered in an observation unit under authority of a waiver issued by the OHSM. However, please note that pursuant to the recently adopted regulations, facilities that had been granted a waiver are required to comply with the provisions of the new regulatory standards within 24 months of the effective date of the regulation change (i.e., January 11, 2014). Facilities that are not in compliance with the regulations by January 11, 2014, will not be eligible for reimbursement.Previously published billing instructions for observation services may be found in the May 2011 Medicaid Update at:Please contact the Division of Certification and Surveillance at (518) , if you have questions about the process for establishing an observation unit or operating standards.If you have questions about Medicaid reimbursement for observation services, please contact the Division of Program Development and Management at (518)NY State Medicare Update, February 2012,
13Changes Effective April 1, 2013 Impacts NY Medicaid, including FFS, Medicaid Managed Care and Family Health PlusExpanded coverage of Observation ServicesObservation services are designed for patients for that cannot be treated and released in the ED, but should reasonably be expected to be discharged within 48 hoursA patient must be in observation at least eight hours (with clinical justification)This is in addition to time spent in the ED prior to receiving observation services“Observation Services Legislation and Medicaid PaymentMedicaid May 2013 Update:Effective April 1, 2013, New York State Medicaid, including Medicaid fee-for-service (FFS), Medicaid Managed Care and Family Health Plus (FHPlus) plans, will expand coverage of observation services. Existing guidelines can be found online at May 2011 Medicaid Update and February 2012 Medicaid Update.In response to legislation enacted October 3, 2012, (Laws of New York, 2012, Chapter 471), regulations governing observation services are being revised. However, in the interim, to obtain payment for observation services providers should bill in accordance with these guidelines.Hospitals may provide observation services for those patients for whom a diagnosis and a determination concerning admission, discharge or transfer cannot be accomplished within eight hours after presenting in the Emergency Department (ED), but can reasonably be expectedwithin 48 hours. In order to be reimbursed for observation services, a patient must be in observation status for a minimum of eight hours (with clinical justification). This is in addition to any time that the patient spent in the ED prior to receiving observation services.
14April 2013 Changes Observation services may now be provided in: An approved unit that has an existing waiverAn existing observation unit in compliance with 10 NYCRRNew distinct observation unit in compliance with 10 NYCRRInpatient bed (i.e., “scatter bed”)The ED (for CAH or sole community hospitals)Observation services may be provided up to 48 hours, after which the patient should be admitted or transferred or dischargedObservation services may be provided in:approved units that have existing waivers;existing observation units (in compliance with current regulations at 10 NYCRR (g));new distinct observation units (in compliance with 10 NYCRR (g));inpatient beds; orthe ED (only for hospitals designated as critical access hospitals or sole community hospitals).A patient may remain in observation for up to 48 hours and then the hospital must determine if the patient is to be admitted, transferred to another hospital or discharged from the facility.
15April 2013 ChangesRequired documentation for Medicaid payment for observation includes:A clinical justification for observation statusA working diagnosisTests/treatments administeredProgress notes by physician or mid-level, andFinal disposition of the patientBilling Guidelines and RequirementsThe following Medicaid payment policy and reimbursement criteria will apply concerning Medicaid payment for observation services. Required documentation for Medicaid payment for observation services include:a clinical justification for observation status;a working diagnosis;any tests or treatments administered while the patient is in observation status;progress notes by a responsible Physician, Physician Assistant, Midwife or Nurse Practitioner; andfinal disposition of the patient from staff assigned to observation.
16April 2013 ChangesMust be assigned from the ED or hospital OP department if the facility does not have an EDService is billed with HCPCS code G0378, hospital observation per hourGroups to APG 450Units reported should be number of hours, up to 48Will only be reimbursed if units exceed 8 (that is 8 to 48 hours)Should still be reported even if less than 8Patients may be assigned to observation services through the ED (or hospital outpatient department if the facility does not have an ED). Medicaid covers observation services designated by HCPCS G0378 (hospital observation service, per hour) which groups to Ambulatory Patient Group (APG) 450, and is subject to consolidation and bundling logic. Observation services may be provided for up to 48 hours.Medicaid pays for observation services on an hourly basis for up to 48 hours (excluding time in ED). The number of hours in observation status must be coded in the units of service field of the claim line on which G0378 is coded. The appropriate CPT/HCPCS codes for all ancillary services provided to the patient while in observation status should also be reported on the claim. Facilities will only be paid for observation if the length of stay in observation exceeds eight hours. If the length of stay in observation is less than 8 hours, the stay is not reimbursable by Medicaid. Nevertheless, providers should always comprehensively code all services provided during a visit/episode.
17April 2013 ChangesObservation ends when patient is either discharged or admittedIf patient is admitted, only the inpatient claim should be submitted for paymentCharges from the outpatient part of the visit are included on the inpatient claimIf the patient is transferred, the ED and observation services may be submitted for paymentObservation services end when the patient is admitted as an inpatient, or is discharged from the hospital. If the patient is admitted to inpatient status, only the inpatient admission may be submitted for payment and the emergency room services and associated observation services should not be billed to Medicaid. If the patient must be transferred to another facility, the emergency room and observation services may be submitted for payment.
18April 2013 ChangesTime away from observation should be excluded from the observation timeSignificant procedures such as MRI, PET and CT scans will result in G0378 being packaged (i.e., not paid)Low level ancillaries will allow observation to be paid separatelyNote: Only those hours that the patient is actually in the observation unit may be billed with G0378. Significant procedures or high intensity ancillaries (MRI, PET scans, CT scans) will cause G0378 to package, meaning it will not be paid separately. Low level ancillaries (X-rays, laboratory tests) and drugs will not cause G0378 to package and Observation will be paid separately.
19April 2013 ChangesDiscrete observation unit established in compliance with 10 NYCR reported with the UC modifier – reimbursed at an enhanced rate (20% higher)Scatter bed services reported without the UC modifierOrder for observation must be clear and must clearly identify observation as outpatientPatient must be advised that they are outpatient and the stay does not meet Medicare inpatient requirements for SNF servicesThe UC modifier should be added to the observation claim line if the service is being provided in a discrete observation unit (established in compliance with 10 NYCRR (g)). Facilities will be reimbursed an enhanced hourly rate (i.e., 20 percent higher) for providing observation in designated units if they code the UC modifier. However, observation services provided in non-designated units (i.e., "scattered site beds") should be coded using G0378 without the UC modifier.Patients that are assigned to observation services must be advised of their status, verbally and in writing. This notification must clearly identify observation services as outpatient in nature, and indicate that the services will be subject to outpatient rules and co-payment requirements. The patient must also be advised that outpatient services do not satisfy Medicare inpatient requirements for skilled nursing facility services.Source: May 2013 Medicaid Update,
203M EAPG October 2013 Changes APGs 500-502 are new in 2013 APG 492 is EAPG Type IncidentalAPG 450 is EAPG Type AncillaryAPGs are EAPG Types Medical
21APG Logic for New Observation APGs G0378 maps to APG 450G0379 and other observation CPTs map to APG 492
22Ancillary Observation – APG 450 Billed with G0378, Hospital observation service, per hourPaid with units >= 8, should be <= 48UC modifier if discrete unitTypical rate code 1402, Emergency departmentMust have a medical visit (e.g., 99285)Groups to APG 450, ObservationRelative Weight = (down from , but now is per hour)Payment $24 (upstate) to $31 (downstate) per hourPaid in addition to ED visit, packaged with significant procedures
23Medical Observation – APGs 500, 501, 502 Medical observation APG assignmentMust be reported:A CPT or HCPCS code assigned to APG 492 (e.g., G0379)Plus G0378 which is assigned to ancillary observation APG 450EAPG 492 changes to one of three medical EAPGs (if all criteria met)500 ENCOUNTER/REFERRAL FOR OBSERVATION - OBSTETRICAL501 ENCOUNTER/REFERRAL FOR OBSERVATION - OTHER DIAGNOSES502 ENCOUNTER/REFERRAL FOR OBSERVATION - BEHAVIORAL HEALTHFinal medical observation APG assignment is determined by primary dx codeAPG 450 is packagedObservation is packaged if a significant procedure is reported, e.g., – Fetal Stress Test
24Medicare IPPS Final Rule Changes Effective 10/1/2013 24
25Inpatient Versus Observation Order - Inpatient order must be clear “admit to inpatient” or “admit as an inpatient” – cannot be vague such as “admit to C5”The word “admit” alone is not sufficientLength of Stay - Presumed to be medically necessary if the stay crossed two midnights for “medically necessary services”Order must document the expectationLess than two midnights would be presumed to not meet inpatient criteria
26Medical Review Policies Two midnight benchmarkBegins when the patient starts hospital care (i.e., comes into the ED)Two midnight presumptionPresumed to meet medical necessity if the stay was at least two midnightsReviews will focus on inpatients with stays less than two midnights
27Physician Certification Physician certification requiredAuthentication of the order to admitProvides the reason for the inpatient servicesEstimates the time the patient will need to be in the hospital andThe plans for post-hospital careThe physician certification must be completed, signed, and dated and in the medical record prior to dischargeA specific format is not requiredPhysician Certification of inpatient services:Authentication of the practitioner orderReason for inpatient servicesThe estimated time the beneficiary requires or required in the hospitalThe plans for post-hospital careTiming: The certification must be completed, signed, dated and documented in the medical record prior to dischargeAuthorization to sign the certification: The certification or recertification may be signed only by one of the following:(1) A physician who is a doctor of medicine or osteopathy.(2) A dentist in the circumstances specified in 42 CFR (d).(3) A doctor of podiatric medicineFormat:As specified in 42 CFR , no specific procedures or forms are required for certification and recertification statements. The provider may adopt any method that permits verification. The certification and recertification statements may be entered on forms, notes, or records that the appropriate individual signs, or on a special separate form.
28Recent Clarifications For patients transferred in, the receiving hospital can take into account the time spent at the transferring hospital when determining whether the patient met the 2-midnight benchmarkOff-campus ED’s are still considered part of the hospital and time spent in these departments would count into the 2-midnight calculationCMS has requested re-reviews of denials made during the probe audit to ensure they are consistent with these clarificationsSource:1. One of the most significant, and awaited, clarifications relates to patients transferred from another hospital. CMS clarified in its guidance to hospitals that the receiving hospital may take into account the time the patient spent at the transferring hospital when determining whether the patient meets the 2-midnight benchmark for admission. The hospital should be careful not to include any wait time or time when care was delayed. CMS stated that review contractors may request records from the transferring hospital to verify time spent there prior to transfer. 2. There was also a clarification related to off-campus provider-based emergency departments (e.g., freestanding ED). CMS clarified that when these locations are provider-based facilities, they are like any other department of the hospital and time spent in the freestanding ED prior to admission would count into the 2-midnight calculation in the same manner as time in a traditional ED. However, they did note that the transportation of the patient from the freestanding ED to the hospital for admission would be the responsibility of the hospital (i.e., Medicare would not pay for the transport), noting that it would be similar to the patient moving from the on-campus ED to a specified floor for admission.3. Finally, CMS announced that it is requesting the MACs re-review denials made in the probe and educate audits to this point. CMS wants the MACs to be certain that any denials are consistent with the most recent guidance and clarifications issued, particularly related to orders and certification. As a result of a re-review of a denial, the MAC can issue payment without an appeal by the provider if they find the claim is payable in light of the most recent guidance.Because a claim may be paid as a result of a re-review, CMS encouraged providers to verify with the MAC whether a claim had been “re-reviewed” prior to filing an appeal. CMS is waiving the timely filing requirement of 120 days for appeals of denials for claims with dates of service prior to January 30 (when the most recent order and certification guidance was updated) and is allowing appeals to be submitted through September 30, 2014, for those denials if they are not overturned on re-review.
29Rebilling Opportunities When an inpatient stay has been deemed not medically necessary after the beneficiary has been dischargedCould be due to a RAC denial, a MAC denial, a prepayment review, or the provider review itselfBill all services up to the inpatient order as Part B OPPS (bill type 13x)Bill all services after the inpatient order as Inpatient Part B (bill type 12x)Source: NGS website release 5/7/2012
30Medicare Timely Filing Subject to the Timely Filing RuleMedicare defines the timely filing period as no later than 12 months after the date of serviceInpatient claims denied later than this are past the timely filing limit and cannot be corrected and rebilledUnfortunately, many times auditor denials are after the timely filing, in which case the Hospital has no option for recouping paymentChanges the March 13, 2013 CMS ruling70 - Time Limitations for Filing Part A and Part B Claims(Rev. 2140, Issued: , Effective: , Implementation: )Medicare regulations at 42 CFR define the timely filing period for Medicare fee for service claims. In general, such claims must be filed to the appropriate Medicare claims processing contractor no later than 12 months, or 1 calendar year, after the date the services were furnished. (See section §70.7 below for details of the exceptions to the 12 month timely filing limit.)Chapter 1, Medicare Claims Processing Manual, Section 70 – Time Limits for Filing Part A and Part B Claims
31Rebilling Steps Steps to follow: IP Claim - CancelledBill type 110ICD-9 Dx CodesAnd ProceduresIP Part BBill type 121Post IP OrderCPT ProceduresOP ClaimBill type 13xCPT Pre IP Order ProceduresSteps to follow:Submit an inpatient no-payment claim for the inpatient stay using bill type 110Submit an inpatient Part B claim for the billable services that occurred during the inpatient stay using bill type 12XThat is an Inpatient Part B claim for services provided after the inpatient admit orderFinal rule expanded this to include just about all services except services that have to be outpatient such as medical visit services (ED /Observation /G0379), diabetic self management training (DSMT)
32IP Claim - CancelledBill type 110ICD-9 Dx and ProceduresIP Part BBill type 121Post IP OrderCPT ProceduresOP ClaimBill type 13xCPT Pre IP Order ProceduresClarificationSubmit an outpatient claim(s) for the outpatient preadmission services that occurred prior to the non-covered inpatient stay using bill type 13XBased on the fact that the submission of outpatient preadmission services is permitted when there is no Part A payment made for the inpatient stayThat is, the outpatient services are not bound by the 72 hour ruleWould include the ED or clinic visit that occurred prior to the order to admitSource: and
33The BeneficiaryBeneficiaries are entitled to receive information about coinsurance and deductiblesInform beneficiaries in writing that the inpatient stay is not going to be billed to Medicare as a covered claim and whyBeneficiary may be responsible for coinsurance (for the 12X bill and for the 13X bill) instead of an inpatient deductibleIf the inpatient deductible has already been paid, it is the responsibility of the provider to make a refund as appropriateBeneficiaries are entitled to receive information about coinsurance and deductibles. CMS has a duty to protect these rights. The requirement of the decision resulting in a change in patient status be made before the beneficiary is discharged is intended to ensure that the beneficiary is fully informed about the change in status and its impact on the coinsurance and deductible for which the beneficiary would be responsible. For example, if a patient has already met her Part A deductible, then informing the beneficiary a month after discharge that she will now be responsible for additional coinsurance as an outpatient could impose a financial hardship. According to the Conditions of Participation (COP) Section , hospitals are required to protect and promote patient rights.Providers may inform beneficiaries in writing that the inpatient stay is not going to be billed to Medicare as a covered claim and why and that the beneficiary may be responsible for coinsurance (for the 12X bill for the inpatient ancillary services and for the 13X bill for any applicable outpatient preadmission services) instead of an inpatient deductible. If the inpatient deductible has already been paid, it is the responsibility of the provider to make a refund as appropriate.
34Rebilling for Denied Part A Chapter 3 of the Medicare Claims Processing Manual states that hospitals have to bundle most outpatient services performed within 72 hours of an inpatient stay “when Part A payment can be made on the inpatient stay”But this does not apply when no Part A payment can be made on the inpatient claimin that it states that the payment window applies when Part A payment can be made on the inpatient claim, thus concluding that it does not apply when no Part A payment can be made on the inpatient claimSource:
35Inpatient Part B Expansion Expansion of services that can be billed now includes most services, even PT/OT/STDoes not apply for other circumstances when there is no Part A payment such as when Part A benefits have been exhaustedDoes not include observation since unless there is an order for observation prior to the order for inpatient (in which case it would be billed on the 13x bill)List of rev codes not covered, see MLN Matters SE1333,
36Condition Code 44 Order Inpatient Observation Must occur Prior to DischargeCM / UR physician advisor / Attending physician all involved in decisionShould be relatively rareRequires signature of both UR and Attending physiciansMust notify the patient (signed document suggested) what it means to be an observation caseObservation time starts with the observation order changeOften not w/ the required 8 hoursResult is a bill type 131 outpatient claim
37Current Medicare Rules Observation Coding, Billing and Payment 37
38Observation is a Timed Service Reported by the hour – rounded to the nearest hourStarts: physician order time and date and observation treatment has startedClear order to admit as inpatient Vs. refer to observationNursing documentation indicating observation care has startedEnds: physician order time and date to discharge from observation or hospital and medical treatment has endedNote that “discharge after consult” or other critical, but delayed medical test should be clearly documented“Waiting for a ride” is not considered part of observation timeReporting Hours of Observation(Rev. 2234, Issued: , Effective: , Implementation: )Observation time begins at the clock time documented in the patient’s medical record, which coincides with the time that observation care is initiated in accordance with a physician’s order. Hospitals should round to the nearest hour. For example, a patient who began receiving observation services at 3:03 p.m. according to the nurses’ notes and was discharged to home at 9:45 p.m. when observation care and other outpatient services were completed, should have a “7” placed in the units field of the reported observation HCPCS code. (Chapter 4, Medicare Claims Processing Manual)Chapter 4, Medicare Claims Processing Manual,
39Observation is a Timed Service Does not include time that is:Concurrent with diagnostic testing or therapeutic services that includes active monitoring, “(e.g., colonoscopy, chemotherapy)”, orServices that are part of another service (e.g., PACU)Need to implement a system to extract other procedural time from observation hoursGeneral standing orders for observation services following all outpatient surgery are not recognized. Hospitals should not report as observation care, services that are part of another Part B service, such as postoperative monitoring during a standard recovery period (e.g., 4-6 hours), which should be billed as recovery room services. Similarly, in the case of patients who undergo diagnostic testing in a hospital outpatient department, routine preparation services furnished prior to the testing and recovery afterwards are included in the payments for those diagnostic services.Observation services should not be billed concurrently with diagnostic or therapeutic services for which active monitoring is a part of the procedure (e.g., colonoscopy, chemotherapy). In situations where such a procedure interrupts observation services, hospitals may determine the most appropriate way to account for this time. For example, a hospital may record for each period of observation services the beginning and ending times during the hospital outpatient encounter and add the length of time for the periods of observation services together to reach the total number of units reported on the claim for the hourly observation services HCPCS code G0378 (Hospital observation service, per hour). A hospital may also deduct the average length of time of the interrupting procedure, from the total duration of time that the patient receives observation services.Observation time ends when all medically necessary services related to observation care are completed. For example, this could be before discharge when the need for observation has ended, but other medically necessary services not meeting the definition of observation care are provided (in which case, the additional medically necessary services would be billed separately or included as part of the emergency department or clinic visit). Alternatively, the end time of observation services may coincide with the time the patient is actually discharged from the hospital or admitted as an inpatient. Observation time may include medically necessary services and follow-up care provided after the time that the physician writes the discharge order, but before the patient is discharged. However, reported observation time would not include the time patients remain in the hospital after treatment is finished for reasons such as waiting for transportation home.If a period of observation spans more than 1 calendar day, all of the hours for the entire period of observation must be included on a single line and the date of service for that line is the date that observation care begins. Source, Medicare Claims Processing Manual, Chapter 4 -
40Reporting Observation If a period of observation spans more than one (1) calendar day, all of the hours for the entire period of observation must be included on a single line and the date of service for that line is the date that observation care beginsSource, Medicare Claims Processing Manual, Chapter 4 -
41Reporting Infusions“Drug administration services are to be reported with a line item date of service on the day they are provided. In addition, only one initial drug administration service is to be reported per vascular access site per encounter, including during an encounter where observation services span more than 1 calendar day.”Source, CMS Medicare Claims Processing Manual, Chapter 4, Section 230.2,
42Reporting Observation Medicare reportingRevenue code 762, observationG0378, Hospital observation service, per hourUnits - The number of hoursTime must be calculatedSuggest a documentation review required to ensure accurate reporting of unitsIf calculated automatically, perform an internal audit on at least a select number of cases
43Observation CoverageShould not be billed for monitoring and care during standard postoperative recovery period (e.g., 4-6 hrs)Can be billed for complications requiring extended post-surgical recovery careBut will not be reimbursed for the composite rate when there is a surgery prior to the observationNeeds to be ordered43
44Observation PaymentExtended Assessment and Management composite payment that covers an episode of care involving more intense assessment and management, includes:A high-level clinic or ED visit, direct referral to observation, or critical care service8 hours or more of observation servicesOther associated services (packaged)
45Observation Changes for 2014 Significant increase in packaged services (e.g., lab and stress tests)Reduction of clinic E/M codes to a single G code (G0463)Required changes to observation compositesNot updated for 2013
46Extended Assessment and Management Composite (EAM) In 2013 there were two composite EAMs – 8002 and 8003
47Level I Extended Assessment and Management - APC 8002 G0378 (8 or more units)Revenue code 762 (observation)Reported with:G0379 (direct referral) on the same date of service, or99205 / (level V clinic visit) on the same date or day beforeReported without a surgical (Status T) procedure on the same day or day beforeNational APC Rate (2013) = $440.70No diagnosis requirement
48Level II Extended Assessment and Management APC 8003 G0378 (8 or more units)Revenue code 762 (observation)Reported with:99284 / (high-level ED visit), or99291 (critical care), orG0384 (high level Type B ED visit)On the same day or day before the observationReported without a surgical (Status T) procedure on the same day or day beforeNational APC Rate (2013) = $798.47No diagnosis requirementHigh Level E/M
49Extended Assessment and Management Composite (EAM) Effective 1/1/2014 there will be only one composite EAM – 8009G0378 (8 or more units), revenue code 762 (observation) with no diagnosis requirementReported with an E/M service:99284 / (high-level ED visit) (critical care)G0384 (high level Type B ED visit) G0463 (clinic E/M)Or G0379 (direct referral to observation from physician ofc)On the same day or day before the observationReported without a surgical (Status T) procedure on the same day or day beforeNational APC Rate (2014) = $1,198.91
51G0379 – Direct ReferalG0379 – Direct referral to observation, moved to APC 608, payment increased to $ (2014) from $ (2013)reimbursed as a (APC 604)reimbursed as a – new patient clinic level V2014 – reimbursed between a level IV and V ED E/MPaid only when observation is not paidImproved reflection of the cost associatedwith direct referrals to observation
52What this means to Medicare Observation Increased composite reimbursementExtensive bundling of servicesAdd-ons, ancillaries, lab and drugs not separately paidComposite payment increases, but packaging of services increases as well
53SummaryObservation is payable by both Medicare and Medicaid as an outpatient serviceImpacts reimbursement for hospital and cost for patientsThere are specific requirements that must be met to bill observation correctlySignificant changes started in OctoberMore changes were made in January
58CPT®Current Procedural Terminology (CPT®) Copyright 2013 American Medical Association All Rights Reserved Registered trademark of the AMA58
59DisclaimerInformation and opinions included in this presentation are provided based on our interpretation of current available regulatory resources. No representation is made as to the completeness or accuracy of the information. Please refer to your payer or specific regulatory guidelines as necessary.