Medicare Compliance & Reimbursement - 2015 Issue 6
Emergency Department E/M: Don't Let Lack of Official Guidelines Waylay Your Facility Coding Compliance
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Article Overview
This article is for hospital coders, compliance staff, auditors, and provider education teams who need a practical understanding of emergency department facility E/M level assignment under CMS outpatient payment guidance. It reviews the source of CMS direction, the framework hospitals are expected to use when creating local facility guidelines, the difference between facility and professional coding approaches, documentation and medical necessity considerations, and common models used to support internal policies and audit review.
Why This Topic Matters
Emergency department facility coding affects payment, compliance, and audit exposure, so hospitals need a defensible local methodology when national instructions are limited. Understanding the broad CMS expectations and the types of guideline models discussed in the article can help organizations align their internal processes with compliance requirements.
Article Sections
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Differentiate Professional and Facility
Introduces the distinction between physician professional services and hospital facility services in the emergency department setting. It also frames the CMS outpatient payment context that the article discusses.
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Make Sure You Also Document Medical Necessity
Focuses on the role of clinically necessary documentation and medical necessity in facility guideline design. It addresses the need to avoid documentation practices that could create compliance concerns.
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Put Your Facility Guidelines In Writing
Covers the importance of formalizing hospital facility guidelines, applying them consistently, and retaining them for review. It also touches on audit and contractor review readiness.
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Consider These Options
Describes general categories of facility guideline models discussed in the article and the flexibility hospitals may have in selecting an approach. It also notes the role of annual review and internal analysis in maintaining compliance.
What You Will Learn
- How CMS OPPS guidance relates to emergency department facility E/M coding
- What broad characteristics hospital facility guidelines are expected to have
- How facility and professional E/M approaches differ at a high level
- Why medical necessity and documentation standards matter for compliance
- What general types of ED facility guideline models are mentioned in the article
- Why written, consistent, and reviewable policies are important for audits
Who Should Read This
- Hospital coders
- Compliance officers
- Revenue cycle staff
- Clinical documentation improvement teams
- Auditors
- Provider education staff
Codes Discussed
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