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COMPLIANCE issues must always use the Pos code where the beneficiary is receiving care as a registered inpatient or outpatient of the hospital, regardless of where the beneficiary receives the faceto face service. therefore, if a physician is providing care or services to a hospital or facility (inpatient or outpatient), the Pos code will reflect that designation. the latest transmittal reiterates that, at a minimum, the reporting of the inpatient hospital (Pos 21) or outpatient hospital (Pos 22) should be utilized to trigger the facility payment rate. however, if the provider is aware of the exact setting or the beneficiary is a registered inpatient or outpatient, then the appropriate facility Pos is to be utilized. some of the examples provided include emergency department (Pos 23), skilled nursing facility (Pos 51), and ambulatory surgical center (Pos 24). the major goal is to ensure that at a minimum, the facility inpatient or outpatient designation be applied with the most exact facility Pos applied as is known to the provider, again noting that Pos 22 or 21 may serve as the minimum requirement. the instructions move beyond the application of the Pos code, and further clarify the service location designation instructions. cms’s mln matters® number mm7631, reminds providers that: "… under the mPfs, payment amounts are based on the relative resources required to provide services and vary among payment localities as resource costs vary geographically as measured by the geographic practice cost indices (gPcis). the payment locality is determined based on the locations where a specific service code was furnished. for purposes of determining the appropriate payment locality, cms requires that the address, including the ZiP code for each service code, be included on the claim form in order to determine the appropriate payment locality… entered in item 32 on the paper claim… (or its electronic equivalent).” What does that mean? typically for most mPfs services, the location where the provider saw the patient would be entered on the claim form in box 32, but that poses some difficulties for those “remote” services such as the Pc of diagnostic tests that may be done without face-to-face visits. What is now required or clarified for the billing of those services? the guidance specifically clarifies service location submission hbma has re-designed the certification program to encourage excellence through education and awareness of the billing industry. attaining this distinction requires attendance and participation in hbma sponsored programs. initial chbme certification requires 60 hours of credits, including attendance at 3 national conferences. maintaining chbme certification requires 60 credits over a 3 year period and attendance at 2 national conferences. the 2013 fall annual conference offers you the opportunity to acquire 14.0 hours of credit toward your chbme designation. the two pre-conference programs afford 4.0 additional credit hours each. Elevate your professional stature and gain a competitive edge by pursuing certification as a CHBME! the certification program designed to encourage excellence within the hbma membership through education and awareness of our industry. the journal of the healthcare billing and management association 43


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