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NYUMC Office of Compliance |
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If it concerns you, it concerns us. |
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NYUHC Regulatory Information Bulletin |
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Volume 2, Issue 2 |
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Fascinating Additions to Federal Law . . . |
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· CMS issued the final intergovernmental transfer rule this week. It establishes a limit on Medicaid payments to public hospitals and further narrows the definition of what entities qualify as public hospitals. · Reminder: the new Conditions of Participation for Transplant Centers outlining hospital requirements for certification in renal and extra-renal transplant become effective June 28, 2007. · CMS issued guidance document to help Providers understand how to obtain the National Provider Identifiers (NPIs) of other Providers. · Revised Medicare Guides for Physicians and Residents now available for download. · CMS released the final text of the “Important Message from Medicare,” which is to be distributed at admission and discharge starting July 2, 2007. · CMS Updated the Inpatient Psychiatric Facility Prospective Payment System for Rate Year 2008. · Guidelines for the Payment of Diabetes Self-Management Training have been updated. |
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The RIB is e-mailed monthly to managers and above. To remove your name from our mailing list, or for questions or comments, please e-mail the Office of Compliance’s Regulatory Information & Education area or call (212) 404-4070. |
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On Saturday May 5th, Governor Spitzer signed “Jonathan’s Law,” which unseals certain records and documents related to patient incidents and investigations pertaining to allegations of abuse and mistreatment of mentally disabled individuals. Specifically, Jonathan’s Law requires parents, guardians, or other qualified persons to be informed within 24 hours of the initial report of an incident that affects the health or safety of a mentally disabled patient. Based on recommendations from GNYHA, Governor Spitzer has urged to make some modifications to that law in order to protect the patient even better. |
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Notable New York Laws & Regulations . . . |
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· MM5520: Payment for Administering and Discarding Single Use Vials · Physician Quality Report Initiative codes for reporting effective July 1, 2007. · Proposed rule to eliminate Federal Medicaid matching payments for the costs of graduate medical education. · Proposed Compliance Program Requirements for Part D and Medicare Advantage Programs · CMS requests comments on revised ABN by 6/24/07. |
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June 1, 2007 |
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Compliance Risks Inherent in EMR Systems With Pre-populated Templates Clinical users love electronic medical record (EMR) templates because they make documentation faster and easier, but abuses, such as cloning and “exploding” notes, may jeopardize reimbursement and compliance. Cloning occurs when too much information is replicated from one record to the next. Since cloning makes it difficult to establish medical necessity, Medicare carriers have frowned upon what they call default documentation for years. Some compliance professionals warn that anything that puts in clinical information independent of the provider is a compliance risk. While cloning may work for some elements of the history, it should not be used for the history of the present illness, the exam or medical decision making portion. Exploding notes are notes that are created based on a healthcare professional checking off “normal” or “negative” to a series of questions. The bottom line is that the medical record needs to be customized to the greatest extent possible so that auditor’s can easily see they are not duplicate or carbon-copy records. For more on this topic . . . Click here. |
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After a four-month hiatus, due to extended leave, the RIB is back with interesting and necessary items to keep you informed. As we progress through this year, healthcare spending continues to be a hot topic and regulatory bodies continue to look for ways to recoup lost dollars. More than ever, regulatory compliance can help save us money! |
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Editor’s Corner! |
