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Compliance

Overview

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

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.

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 2023

American Medical Association Medical Decision Making (MDM) Table, Effective January 1, 2023

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Policy Update on 2022 Medicare Split (or Shared) Billing Rule

One-pager on recently finalized rules for split (or shared) billing of hospital visits between physicians and NPs/PAs. Updated Nov 2022.

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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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Hospitalist Specialty Code

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.

Access PECOS

Observation Care Rules

Two-Midnight Rule

Medicare promulgated the Two-Midnight Rule in 2013 in response to the rise in number and length of observation stays. The rule is intended to provide a clear time-based threshold for when a patient should and should not be admitted as an inpatient. Any patient whose hospital stay is expected to cover at least two midnights is generally considered inpatient, while any patient who requires less than two midnights would be observation.

The Two-Midnight Rule has been highly controversial since its enforcement. In conjunction with our Government Relations department, our resources accessible below will help hospitalists understand, apply and advocate for improvements regarding observation care.

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Buprenorphine Practice Guidelines

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, all health care practitioners who apply newly for or seek to renew their DEA registration will be required to take an 8 hour government‐approved course in understanding and treating addiction. This training requirement goes into effect on June 21, 2023. More guidance will be released by the DEA and SAMHSA in the coming months.

 

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 DEA and SAMHSA:

 

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.

View Recording

 

Read more about Buprenorphine Practice Guidelines