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Don’t assume you are not being scrutinized
Implementing ambulatory payment classifications (APCs) under the outpatient prospective payment system means widespread changes through every health care system. But don’t assume you have a year to get in step with compliance issues, warns Julie Micheletti, director of clinical product strategies for HSS, in Camden, CT.
"Even though the Office of the Inspector General says it will not touch the [outpatient prospective payment coding] area in the first year . . . I still think there is risk," Micheletti says. "We have not been careful on the outpatient side in the past and now we have to be."
The Health Care Financing Administration (HCFA) will have the data to look at the increased volume of APCs that have higher levels, she adds. She suspects HCFA may examine the level of terminated procedures for suspected inappropriateness. "There is also the risk of duplicate billing because of coding confusion," she adds. Overall, she says, this area is "rife with a series of compliance issues that will surface next year."