Observations, questions and answers during a week of pontification.
So what’s new this week? In a previous Monitor Monday, I mentioned the recently released 2022 Medicare Payment Advisory Commission report to Congress that addressed several site neutral payment proposals. One other tidbit from that report is that they have suggested to the Centers for Medicare & Medicaid Services (CMS) that ED visits, critical care visits and trauma care facility charges be converted from standard APCs to Comprehensive APCs.
That means the hospital would get one single payment for the ED patient who is not subsequently admitted to the hospital, just as Medicare now pays for outpatient surgery and outpatient care with observation services. With this proposal, if the ED physician does no CT scans or three CT scans and an MRI, no labs or a whole panel of labs, it is that one same payment. Once again, their motivation is to save Medicare money, but one must wonder at what cost? How many trauma centers will become financially nonviable if trauma visits are paid at one set level and lead to limited access to trauma care?
Next, I have been talking a lot about observation and billing. And that’s because there is a lot to talk about. It’s confusing. But last week I got an email from a hospital that was one of those “aha” moments. This person was inquiring about the observation patient that stays a few hours after they have been determined stable for discharge. Now for most hospitals Medicare pays the observation visit as a comprehensive APC, one fixed price so a few extra hours does not affect payment in most cases. But this hospital gets paid based on a percent of charges. That means that if an observation patient stays an additional six hours waiting for a ride and is not formally discharged until their ride arrives, as is routine in most hospitals, this hospital gets paid more money for the visit.
The Claims Processing Manual says “Billing ends when all clinical or medical interventions have been completed including care after the discharge order has been given” so that is not much help. Should these hours be billed as observation and paid as such? I am not so sure. Billing any unnecessary services is problematic but when there is actual direct revenue implication, it seems more significant.
Finally, last week I was talking to a group about my other favorite topic, the admission status of patients having elective joint replacement. And I was asked what was the benchmark inpatient admission rate?
Well, that was just the opening I needed to provide my definitions of a key performance indicator (KPI) and a benchmark. A key performance indicator is a random measurement of something/anything that can be easily generated by a hospital computer system with a couple of clicks that the C-suite has been convinced means something and a benchmark is an arbitrary target for that KPI set by someone with a cursory knowledge of the facts.
Of course, these definitions represent the epitome of my well-known negativism and should be taken with a grain of salt, but the request for a benchmark rate of inpatient admissions is a great example. Now what I was able to tell the questioner is that in 2021, the average inpatient percent was 30 to 35 percent. But in no way is that the right rate for any one facility. The benchmark rate is when every patient is placed in the right status every time. That is the goal to which we should all strive.
Dr. Ronald Hirsch is Vice President of the Regulations and Education Group at R1 RCM Inc. Dr. Hirsch was a general internist and HIV specialist and practiced at Signature Medical Associates, a multispecialty practice located in Elgin, IL. He was Medical Director of Case Management at Sherman Hospital in Elgin, IL from 2006 to 2012, where he was Chairman of the Medical Records Committee from 1995 to 2012, and also served on the Medical Executive Committee. Dr. Hirsch is certified in Health Care Quality and Management by the American Board of Quality Assurance and Utilization Review Physicians, certified in Revenue Integrity by the National Association of Healthcare Revenue Integrity, and on the Advisory Board of the American College of Physician Advisors. He is on the editorial board of RACmonitor.com. He is the co-author of The Hospital Guide to Contemporary Utilization Review, with the third edition published in 2021.