Implementation of national guidelines for reporting hospital outpatient clinic visits would lead to standardized and consistent auditing of hospitals’ billing practices for clinic and emergency department visits. The result would be easier identification of potential inappropriate practices requiring additional action.
This was the recommendation delivered by AHIMA in a Sept. 6 comment letter to Marilyn Tavenner, administrator of the Centers for Medicare & Medicaid Services (CMS), on the CMS’ proposed Hospital Outpatient Prospective and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs; Hospital Value-based Purchasing Program.
“AHIMA stands ready to work with CMS, the American Hospital Association, and other important stakeholders to collaboratively update the set of guidelines for clinic and emergency department visits and then adopt them as the set of national guidelines for visit code reporting under the OPPS,” said AHIMA CEO Lynne Thomas Gordon, MBA, RHIA, CAE, FACHE, FAHIMA.
AHIMA supports CMS’ proposed elimination of the distinction between new and established patients for clinic visits, but does not believe the proposed new codes would adequately document and distinguish outpatient visits.
“It is important for health information management (HIM) professionals and CMS to capture specific, detailed data on these visits, which ultimately will provide patients with the best possible care at the lowest cost,” Thomas Gordon said.
AHIMA recommends establishing three levels within each visit category rather than five. This would allow for distinction in clinical complexity and resource utilization. It would also facilitate consistency in visit code reporting and auditing as well as promulgate national guidelines for reporting these clinic and emergency department visit levels.
AHIMA also is ready to work with CMS and other stakeholders on demonstration or revaluation projects to verify data through demonstration or other projects that review the comparability of results of manually abstracted measures with electronically specified/EHR extracted measures.
Additionally, AHIMA recommended and supported the following:
• paced approach to the adoption of additional quality measures and accompanying alignment with meaningful use, development of standards, interoperability framework, and health information exchange networks to support quality measurement; and
• CMS’ efforts to move toward greater alignment and harmonization across the Hospital Outpatient Quality Reporting and Ambulatory Surgical Center Quality Reporting Programs.