Billing and Documentation

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CMS proposed rule change

  • 1.  CMS proposed rule change

    Posted 08-18-2021 16:11
      |   view attached
    Dear members,

    As discussed at the KEG meeting today, please see the proposed CMS rule.
    David Carpenter and I are working with the SCCM leadership to review this and evaluate the opportunity to respond(if needed).
    Please reach out to David Carpenter or myself, if you have any questions, comments or suggestions.

    Piyush

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    Piyush Mathur
    The Cleveland Clinic
    Cleveland OH
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  • 2.  RE: CMS proposed rule change

    Posted 08-23-2021 19:45
    I have some concerns.

    1. I agree shared billing makes sense given the collaborative nature of critical care, particularly between APP/physicians, although if the provider who does >50% of the service has to bill (which would usually be the APP in my setting as it covers pre-rounding and family discussions etc) - then the benefit of shared/split billing (ie.100% of PFS) would be lost. 

    2. "Additionally, we are proposing to prohibit practitioners from reporting critical care visits during the same time-period as a procedure with a global surgical period." - it doesn't specify, but does this mean the same provider can't bill the global period AND critical care (ie.surgical team), or ANY provider can't bill critical care during surgical global period (24/7 CCM team in postop period) -- which would not make much sense to me. 

    Look forward to hearing everyone's thoughts.

    -Gen

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    Genevieve Dobrushin
    Chief CRNP - Critical Care
    Allegheny General Hospital
    Pittsburgh PA
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  • 3.  RE: CMS proposed rule change

    Posted 08-30-2021 07:48
    Thanks Genevieve.
    Please share the word and have other SCCM members join us too!

    Piyush

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    Piyush Mathur
    The Cleveland Clinic
    Cleveland OH
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