Coding & Compliance - August/September 2010
“Medicare Law Clarifies Inpatient 3 Day Payment Window”
The "Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010" seeks to bring more consistency to what is known as the "3 day payment window". This law, which was signed into effect on June 25, 2010 by President Obama, seeks to bring Medicare billing policies into alignment with the traditional hospital billing practices that have been in effect since 1991.
According to the "3 day payment window", hospitals may bill Medicare for outpatient services provided on either the day of an inpatient admission or during the three days preceding admission. Therefore, when billing Medicare for an inpatient stay, hospitals are to include the charges for all diagnostic services and non-diagnostic services provided during the "3 day payment window" that are related to the inpatient stay.
The new law doesn't address billing or charges for diagnostic services. However, it specifies that the phrase "other services related to the admission" refers to all services that are not diagnostic services, for which payment may be made by Medicare that are rendered to a patient on the same day as the patient's hospital admission, or in the three days immediately prior to inpatient admission.
If a hospital bills Medicare separately for services rendered to a patient that was subsequently admitted to inpatient care, the hospital must demonstrate that the services performed were not related to the inpatient admission. The hospital must have documentation to support this decision, and all separately billed services may be subject to review by CMS.
This is effective only for services provided on or after June 25, 2010. Hospitals are advised to include the charges for all diagnostic and non-diagnostic services that they believe fall under the parameters of this provision. CMS has stated that in the near future they will provide instructions on how to bill for therapeutic service that fall during the 3 day or 1 day payment window.
If you have any questions or need additional information regarding this article, please contact Cindy Tipton-Cain at Cindy_Cain@MED3000.com
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