How to Address Ambiguous Guidance under Medicare

Event Information
Product Format
Prerecorded Event
Presenter(s)
Conference Date
Thu, Nov 08, 2018
Length
90 minutes
Product Description

Learn What You Should Do When the CMS Guidance is Not Explicit


The CMS is not always precise in providing guidance on both regulatory and sub-regulatory issues. And in some cases, the regulatory body will not answer specific questions relative to proper metrics that should be used for auditing to ensure compliance. As a result of this ambiguous guidance, hospitals, clinics, and other healthcare providers often struggle to develop policies and procedures to handle key issues relative to Medicare. This can lead to adverse audits and payment recoupments. How do you avoid this?

Learn how in this audio conference with Duane C. Abbey. Abbey will walk you through the issues where the guidance from CMS is ambiguous, tell you what you should do, and explain why you should have written policies and procedures in place (hint: they can help provide compliance protection).

Abbey will show how ambiguous guidance can impact your Medicare audits and lead to recoupment of alleged overpayments, as well as how it can shift the burden of proof to you. He will discuss the concepts of active monitoring and immediate availability; the current status of related services of the 3-day pre-admission window; the evolving interpretations under the provider-based rule; the possible audit guidelines for meeting the over 2-midnight rule; and the difference between clarifying guidance and changed guidance. He will also get you clear on what exactly the over 2-midnight rule really says, and the difference between separately charging and separately billing.

After attending this session, you will be current with the issues where the CMS guidance is ambiguous, and more confident in your ability to handle the key issues relative to Medicare. Plus, you’ll be in a better position to develop policies and implement procedures even when the guidance is not explicit.

Session Highlights

In this session, you will learn:

  • Why you should have written policies and procedures?
  • What is the difference between regulatory and sub regulatory guidance?
  • Why should you worry if CMS cannot make up their minds as to what the rules really mean?
  • What if you make decisions today that are not correct three or four years from now?
  • How can anyone audit without specific guidelines?
  • What does active monitoring mean for reducing observation hours?
  • Why has CMS clarified the requirements for physician supervision of all outpatient therapeutic services?
  • Is the ‘Over 2-Midnight’ rule a payment rule or a clinical rule?
  • What is the difference between the words ‘clarifying’, ‘changing’ and ‘reinterpreting’?
  • What does immediate availability really mean?
  • For the 3-day payment window, how do you know which therapeutic services are related to the admission?
  • For the charge master, what is the difference between separately charging and separately billing and how does this affect policy and procedure development?

Session Objectives

After attending this session, you will be able to:

  • Discuss CMS’ ambiguous guidance
  • Know how ambiguous guidance can affect Medicare audits and recoupment of alleged overpayments
  • Know how regulatory and sub regulatory guidance affects policy and procedure development
  • Understand the importance of developing written policies and associated procedure to implement policies
  • Appreciate the challenges in developing interpretations of CMS guidance that will most likely meet the federal audits
  • Know the concepts of active monitoring for counting observation hours; and immediate availability for physician/practitioner supervision
  • Know the current status of related services under the 3-day pre-admission window
  • Understand the evolving interpretations under the provider-based rule
  • Understand the possible audit guidelines for meeting the ‘Over 2-Midnight Rule’
  • Appreciate the difference between clarifying guidance and changed guidance
  • Understand what the over 2-midnight rule really says
  • Know the difference between separately charging and separately billing

Who Should Attend

  • Compliance officers
  • Compliance analysts
  • RAC coordinators
  • Clinical directors/managers
  • Physicians
  • Practitioners
  • Nurses
  • Information technology personnel
  • Computer analysts
  • Health information management personnel
  • Charge master coordinators
  • Revenue cycle specialists, and
  • Internal auditors

Ask a question at the Q&A session following the live event and get advice unique to your situation, directly from our expert speaker.

Order Below or Call 1-866-458-2965 Today

You can also order through:
Phone

1-866-458-2965

Fax

1-919-287-2643

About Our Speaker

Duane Abbey Hospital Coding & Compliance Expert

 Duane C. Abbey, Ph.D. is a management consultant and president of Abbey & Abbey, Consultants, Inc., which specializes in healthcare consulting and related areas. Duane earned his graduate degrees at the University of Notre Dame and Iowa State University and has more than 20 years of experience as a consultant. He performs various types of financial analysis involving business structuring, organizational development, enrolment and other financially related concerns of organizations....   More Info
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