Compliance

Understanding and maintaining compliance with laws and regulations are necessary for the practice of hospital medicine. The resources below focus on many of the critical policies that impact hospital medicine and help hospitalists navigate the ever-growing and changing regulatory complexities of modern healthcare.

SHM’s Practice Management department works together with the Government Relations team to ensure hospitalist perspectives and experiences are represented and included in federal policy decisions. See more about SHM’s current advocacy efforts. 

Coding, clinical documentation and reimbursement are all foundational concepts necessary for any hospital medicine practice. Hospitalists cannot always bill for everything they do, but they can document and code completely and accurately to ensure their work is appropriately reimbursed.

2024 Policy Update on Medicare Policy on Split (or Shared) Billing for E/M Services

One-pager on the finalized rule for 2024 which contains significant changes for split (or shared) billing for E/M services, specifically that the substantive portion of the split service is defined as more than half of time or substantive part of medical decision making. 

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2023 Changes to the Hospitalist Evaluation and Management Codes

One-pager on the changes to the Hospital Medicine E/M Codes that go into effect January 1, 2023, including the elimination of observation codes, revisions to the inpatient codes, changes in how to bill and document for visits, and adjustments to wRVUs.

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Webinar: 2023 Changes to Hospitalist E/M Billing and Coding

In this webinar, recorded in December of 2022, the speakers discuss the significant changes to the Hospitalist E/M Coding effective January 1, 2023. Hear more about these changes, including elimination of observation codes, revisions to the inpatient codes, changes in how to bill and document for visits, and adjustments to wRVUs, and how the experts are preparing for the new rules.

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AMA MDM Table 2024

A modified version of the American Medical Association Medical Decision Making (MDM) Table, Effective January 1, 2023.  This resource specifically addresses the hospital medicine E/M codes and provides relevant risk examples. 

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Utilization Management and Clinical Documentation

Document with improved accuracy and quality with SHM's Utilization Management and Clinical Documentation for Hospitalists.

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Clinical Documentation Pearls for Hospitalists

A small printable guide to help hospitalists document with consistency and clarity.

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On April 3, 2017, the Centers for Medicare & Medicaid Services (CMS) assigned a specialty code, “C6” for providers that identify themselves as hospitalists. In a monumental step, hospitalists can now differentiate and properly benchmark their performance against other specialties, such as internal medicine and family medicine. Using this specialty code allows for more opportunities to be rewarded while simultaneously minimizing unnecessary penalties.

“This major milestone for hospital medicine demonstrates the continued growth and impact of the specialty.”
– Dea Robinson, FACMPE, Practice Management Committee Member

Due to the persistent efforts of SHM’s Board of Directors, staff and Public Policy Committee, a formal application proposing the need for a hospitalist specialty code – a code that would never have even been considered – was approved. Hospital medicine is the first medical specialty to be granted a specialty code without also having a board certification.

A provider can designate their specialty as “hospitalist” in Medicare’s provider enrollment system (Provider Enrollment, Chain and Ownership System; PECOS). Hospitalists may need to work with their credentialing team and administrators to enact this change for their Medicare enrollment.

Effective January 2023, all health care providers with a DEA registration that includes Schedule III authority can prescribe buprenorphine to treat patients with Opioid Use Disorder. An X-Waiver is no longer required to prescribe buprenorphine. This change follows the passage of the Mainstreaming Addiction Treatment (MAT) Act in December 2022.

In addition, per the Medication Access and Training Expansion (MATE) Act, starting June 27, 2023 all health care practitioners who apply newly for or seek to renew their DEA registration will be required to complete 8 hours of relevant accredited education related to the prevention, recognition, and care of people with substance use disorders. The 8 hours can be satisfied through a combination of activities and do not have to be included in one session.

For more information, including links to SHM activities that count towards the attestation of training completion, please visit DEA Licensure Requirement.

How did we get here?

In 2000, Congress passed the Drug Addiction Treatment Act (DATA 2000), which created the X-Waiver program to enable waivered clinicians to prescribe buprenorphine outside of methadone clinics and similar settings. Because the X-Waiver required additional steps and training, Medication-Assisted Treatment (MAT) with buprenorphine has been underutilized. Since 2018, SHM has advocated for the elimination of the X-Waiver so that hospitalists can more effectively treat patients with opioid use disorder and be able to prescribe this lifesaving medication at discharge.

In December 2022, the omnibus funding package signed by President Joe Biden effectively cancelled the X-Waiver requirements for physicians and NPs/PAs to prescribe buprenorphine.

Below are statements from the SAMHSA:

• SAMHSA: Removal of DATA Waiver (X-Waiver) Requirement

Webinar: How to be a Hospitalist Opioid Use Disorder Champion

2020 was a record year for drug overdose deaths. The hospitalist role in providing effective care for patients with opioid use disorder (OUD) has never been more important. Recent policy changes to the X-Waiver for treating OUD have made it easier for more hospitalists to engage in this work at a critical teachable moment.

In this webinar, two physicians and one physician assistant discussed their experience in becoming OUD treatment champions. Each panelist practices in different regions of the country and shared strategies for obtaining institutional support, identifying community partners for post-discharge treatment linkage, and reducing stigma experienced by patients with OUD. Physician panelists discussed their path to Addiction Medicine Board certification, and opportunities for board certification outside of an Addiction Medicine fellowship program which are available through 2025. Please note that this webinar was recorded in 2021, prior to the X-Waiver elimination in 2023.

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Articles about OUD Treatment

• Implementation of a comprehensive hospitalist-led initiative to improve care for patients with opioid use disorder (article in JHM)
• Hospital Buprenorphine Program for Opioid Use Disorder Is Associated With Increased Inpatient and Outpatient Addiction Treatment (article in JHM)
• The Hospitalist Role in Treating Opioid Use Disorder (article in The Hospitalist)