Welcome to the weekend, and thanks for checking in.

We’re bringing you the news from the past week as well as providing you with a look at the week ahead. And looking ahead, we have a preview of tomorrow’s edition of Monitor Mondays.


HOTEL by the Light of the MOON 

There continues to be buzz about the Centers for Medicare & Medicaid Services’ (CMS) proposed rule that will require hospitals to provide a standard Medicare Outpatient Observation Notice (MOON) that, unlike other notices of non-coverage, does not require the provider to say why Medicare won’t pay. Piling on was a special bulletin this past week by Ronald Hirsch, MD, vice president of Accretive Physician Advisory Services. Dr. Hirsch offers an alternative version—the Hospital Outpatient Time Ending Liability Notice, affectionately called the HOTEL Notice. This will formally notify patients that they will continue to receive care in the hospital but that they are staying as a convenience to themselves, the doctor, or the hospital, and that the hospital will not be expecting payment from Medicare or from the patient for their care for these additional hours or days. The hospital will be instructed to bill the hours as observation hours without medical necessity by using the GZ modifier, as they should be doing now, so that CMS can see how prevalent this is and can better forecast payment rates in the future. CMS may even want to consider an additional modifier to differentiate patient convenience from hospital convenience, since a hospital that does not do stress tests on weekends should not get any special consideration, but caring for a patient for a month to get guardianship and develop a safe discharge plan should be acknowledged. 

QIC Study 

Early this week, a RACmonitor reader and Monitor Monday listener sent me an email complaining about her Quality Integrity Organization (QIO) Livanta. “I was checking on the status of our audit,” she wrote. “Two weeks ago they were ‘just wrapping it up and would be issuing the letter soon.’ Still no letter had arrived today and so I called to check the status. They told me that the audits were currently on hold because CMS had asked them to go back and relook at the cases they had issued findings on and make sure they were interpreting the rule correctly. I asked if they or CMS had announced this yet and I was told that they would be issuing communication shortly.” 

Have any of you heard of this or know specifically about the process for “re-auditing” cases? If so, please send me an email. 


RACmonitor eNews

Here are highlights of several of the articles you’ll be reading next Thursday in the RACmonitor e-news.

How to Mitigate the Risk of Audits: Get Insurance

New York attorney and RACmonitor investigate reporter Ed Roche, PhD, JD, is scheduled to report on how healthcare providers can mitigate the risks of audits by purchasing insurance—RAC insurance. Roche will report on the many types of insurance from which to choose, noting that what is covered varies widely from one policy to another. He will offer basics to help providers be smarter consumers.

Billing for Discarded Waste from a SDV: Assign Modifier JW—now Mandatory—to Retain Revenue

Robin Zweifel with Panacea Healthcare Solutions will report next Thursday about the amount Medicare spends on high-cost drugs. She will write that the Medicare Drug Spending Dashboard has identified many of the drugs and biologicals as being packaged as a single-use or single-dose vial (SDV). Of importance, she notes, is that CMS issued an update mandating the use of modifier JW when billing for discarded waste from a SDV. “It is safe to assume that this transmittal represents another step in containing Medicare spending and in ensuring that the dollars spent can be supported by documentation in the patient medical record,” Zweifel will report.

Upcoming Webcasts

You and your staff are certain to find value in the following upcoming webcasts being produced by RACmonitor.

How to Win Against Auditors Who Use Dirty Tricks Against You

Edward M. Roche, PhD, JD
Wednesday, May 25, 2016
1:30-2:30 pm. ET

Not all contract auditors are bad.  But some are, and they know how to manipulate hospital data to make the facility look like it cheated the federal government. Based on an auditor’s gross manipulation of a hospital’s claims data, a facility could end up owing millions of dollars based on an extrapolation from only 30 claims. In his upcoming webcast, New York attorney Edward Roche, PhD, JD, will reveal how facilities can learn the secrets behind the devious tricks used by unscrupulous contract auditors. Register here.

Avoid Being Wrong on Patient Rights

Ronald Hirsch, MD, FACP, CHCQM
Thursday, June 9, 2016
1:30-2:30 p.m. ET

Knowing how and when to use the right Medicare form will help your facility from providing unreimbursed and medically unnecessary care. Register here.

In Production

Audit Nation: The Documentary: Exposing Investigational Audits

Special Edition Broadcast on Thursday, June 2, 2:00-3:30 PM ET

Senior healthcare analyst Frank Cohen with DoctorsManagement will reveal a sophisticated pre-audit compliance risk application that relies on predictive analytics to minimize false positives, thus ensuring a more efficient audit process. This live broadcast is sponsored by DoctorsManagement.

Share This Article