Based upon discoveries arising partially from recent RAC activity, it has been determined (and verified by CMS) that in an effort to comply with Medicare's 72-hour rule regarding outpatient charges related to inpatient admissions, many hospital organizations have unintentionally violated the regulation by erroneously combining certain "non-diagnostic" and "unrelated" emergency department outpatient charges with the inpatient bill. In addition to exposure from "non-conforming" inpatient claims, another unfortunate consequence for providers who have automatically combined charges or otherwise misinterpreted this rule has been lost revenue, often exceeding hundreds of thousands (if not millions) of dollars in under billed claims. Charges associated with wound care, chemotherapy, and a number of other outpatient procedures may have also been under billed as a result of the misinterpretation of the rule.

A full turnkey solution is now available, however, to assist hospitals in the rapid recovery of this lost revenue. FHA Management Corporation, the for profit company of the Florida Hospital Association (FHA), has partnered with ARx to provide a comprehensive service to identify and recover past under billed Medicare, Medicare HMO and TRICARE claims involving admission from the Emergency Department and, where applicable, charges from other outpatient procedures. CMS is currently allowing for claims dating back to the beginning of Federal fiscal year 2009 (October 1, 2008) to be reviewed. Hospitals have until December 31, 2010 to submit outpatient claims containing the appropriate charges for both 2009 and the first three months of Federal fiscal year 2010 (October 1, 2009 through December 31, 2009).

Outsourcing at least the retrospective review and billing activities prevents the need to place additional burden on the hospital's existing HIM and business office resources. Through FHA Management Corporation's experienced and certified coding staff, and the accomplished hospital billing and business office operations specialists of ARx, a turnkey solution has been designed to facilitate the recovery effort. Included in the solution are the following services:

Coding Review - Identification, separation and documentation of all eligible outpatient charges from the inpatient claim

Billing and Follow up - Adjustment of inpatient claims, per the direction of the FHA coding staff, and all follow up required with the adjudication process. Production and processing of all new outpatient claims and all follow up activity including RTP's and secondary billing

Medicare Underbilling Recovery Service (MURS) Overview

FHA Management Corporation's HIM Services Overview