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Two Laboratory Reimbursement Extensions as Addressed by CMS
JUNE 2010
From Mississippi Medical News, Louisiana Medical News, Medical News of Arkansas, and the Memphis Medical News.
Reasonable Cost Payment for Rural Hospitals and Pathology Technical Component Payment has been in limbo, but recently the CSM addressed in two Medicare Learning Network Matters articles. (See MLN Matters articles SE0931 and MM6873.)
Surgical Pathology Technical Component Sees Daylight after 12/31/09 Sunset
President Obama's new Patient Protection and Affordable Care Act signed March 23, 2010, not only extended the ability of independent laboratories to bill for pathology technical component services to inpatients and outpatients in hospitals, but the provision was also retroactive to January 1, 2010. So if you are an independent lab with denials for services provided in first quarter 2010, the Centers for Medicare & Medicaid Services recommend that you contact your Medicare contractor for re-submission instructions. This 10-year-old battle has been given breathing room for the 2010 calendar year.
Not familiar with the original issues surrounding the technical component billing debate? With the implementation of APCs, the technical component of most procedures and services is packaged into the APC. Many small hospitals with low volume surgical specimens have had long term arrangements with independent labs (or larger hospitals acting as reference labs) to process their pathology samples. Per industry requests, CMS has been "thinking" about this exception and every year or so, extends the "delay" of implementation of moving technical component billing into the APC system. Facilities have had to delay billing of service performed while bills meander through Congress. Once again we have a 12 month postponement.
We'll more than likely be addressing technical components again December 31, 2010.
The link for the official instructions can be found on the CMS Web site at www.cms.gov/MLNMattersArticles
Giving Rural Hospitals a Break with the Clinical Lab Fee Schedule - Again
Are you a rural hospital with fewer than 50 beds - but not a Critical Access Hospital? Well, that same Patient Protection and Affordable Care Act mentioned above gives allows you to take advantage of an opportunity to improve laboratory reimbursement above the Clinical Lab Fee schedule via your cost report.
Not aware of this revenue lifeline? A number of legislative changes since 2004 have provided small "qualified" rural hospitals a way to improve outpatient clinical lab payments. In addition to President Obama's signature on March 23, the Medicare Modernization Act of 2003 (signed February 13, 2004), the Tax Relief and Health Care Act of 2006 (signed February 2, 2007) and the SCHIP Extension Act of 2007 have all provided either the initial bill or extensions of the bill for laboratory claims to be reimbursed "better."
Does your facility qualify? The Medicare Zip Code File will be used to determine those areas with population densities in the lowest quartile of all rural county populations. If you think you may qualify, contact your FI or A/B MAC. Lab services through June 30, 2012, may qualify for some hospitals.
Be sure to notify your finance officers, billers and accountants preparing your cost reports and visit www.cms.gov/Transmittalsfor all the details and references.
Betty Hatten is a manager in health care services at HORNE LLP. Her primary responsibilities include oversight of the chargemaster assessment and maintenance team, as well as providing charge capture audits, performance improvement assessments, and focused compliance reviews. Betty is a frequent seminar presenter and customizes presentations for clients, hospital associations, and professional organizations on the local, regional and national level.
