Payment Policy Update: New for July 1, 2012: Medicare Requires a PD Modifier During The Three Day Payment Window

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Note:  The following article synopsis was NOT provided by AAPC. It was created by Find-A-Code/innoviHealth.

Article Overview

This article reviews a Medicare payment policy update tied to CMS transmittals and the three-day payment window. It discusses the affected service setting, how wholly owned or wholly operated entities are treated, and the reporting changes connected to inpatient admissions and outpatient services. The piece is aimed at coders, billing staff, compliance personnel, and emergency department groups that need to understand the policy update and its implementation context.

Why This Topic Matters

The update affects how services are reported and coordinated around an inpatient admission, especially for hospitals, emergency department groups, and billing teams working across related entities. Understanding the policy helps organizations evaluate whether services fall within the scope of the payment window and align internal billing workflows with CMS guidance.

Article Sections

  1. Background

    Introduces the CMS transmittal history and the Medicare policy context behind the update. It also identifies the broader legislative framework and compliance timing discussed in the article.

  2. The technical component of any ED services must appear on the inpatient claim if delivered within the three day window of an admission

    Explains the article’s focus on services furnished around an inpatient admission and the general claim-level reporting issue involved. It also frames the discussion around outpatient diagnostic and non-diagnostic services within the payment window.

  3. Get The Skinny on Wholly Owned or Wholly Operated Entities

    Covers the organizational relationships addressed in the policy and the regulatory context used to define related entities. It also notes the operational and compliance considerations for hospitals and associated groups.

  4. The Technical Portion of the Diagnostic Service is the Focus of the Change

    Describes the payment policy’s emphasis on the technical portion of services and the categories of services discussed by the article. It also covers how the guidance interacts with inpatient payment concepts.

  5. Use PD Modifier Pre Admission Work During the Three Day Window

    Addresses the reporting update introduced in the transmittal and the operational impact on billing workflows. It also discusses how the article frames related versus unrelated services and the need for payer clarification.

  6. Watch for Future PD Modifier Updates

    Summarizes the open questions and implementation concerns raised by the article. It points to areas where additional CMS guidance was expected.

What You Will Learn

  • The Medicare policy context for the three-day payment window
  • How CMS transmittals are discussed in relation to the update
  • The role of wholly owned and wholly operated entities in the policy
  • How the article frames service reporting around inpatient admissions
  • The general compliance and billing issues raised by the guidance
  • Why the update matters for emergency department and hospital billing teams

Who Should Read This

  • Hospital coders
  • Billing staff
  • Compliance officers
  • Emergency department groups
  • Physician practice administrators
  • Medicare billing professionals

Modifiers Discussed


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