Module 3: Discussion – Assessing Regulatory Risks
Reviewing the Federal Register
Losing the ability to qualify for participation in government programs has serious impacts on any organization. Understanding the governments regulatory requirements and where to find them is critical to successfully assessing risks.
One of many federal regulatory resources to use in your risk assessment process is the CMS Conditions of Participation (CoPs) and Conditions for Coverage (CFCs).
“CMS develops Conditions of Participation (CoPs) and Conditions for Coverage (CFCs) that health care organizations must meet in order to begin and continue participating in the Medicare and Medicaid programs. These health and safety standards are the foundation for improving quality and protecting the health and safety of beneficiaries. CMS also ensures that the standards of accrediting organizations recognized by CMS (through a process called “deeming”) meet or exceed the Medicare standards set forth in the CoPs / CFCs. ”
CMS Conditions for Coverage and Participation Links to an external site.
Select the Hospital link on the left-hand side.
Read the descriiption and move down to the download section on that page.
In the Download section:
Download Appendix A State Operations Manual. This document is the CMS guideline for how Surveyors assess the hospital’s compliance with the CoP for all services, areas and locations in which the provider receives reimbursement for patient care services billed under its provider number. Find section 482.24 Medical Record Services (pp 213 – 239).
In the Related Links section:
Download the Hospital Conditions of Participation – find section 482.24 Medical Record Services
For this week’s discussion:
Describe how the new Coding and Billing vendor has a responsibility to assist the organization in remaining compliant with the Conditions of Participation outlined in the Federal Register regulatory guidance provided.
Defend how you would assess those responsibilities using the survey instructions found in the State Operations Manual.
Cite specific examples found within the Hospital CoP requirements to support your position.
Begin your thread by the deadline and respond to one class member’s posting by Sunday, 2/2 @ 11:59 PM.
Responses that demonstrate critical thinking and especially those that add new relevant material into the discussion will get the highest grades. There is no right or wrong grading. Your grade is based on critical thinking and detailed support for your viewpoint.
For later: Again keeping Assignment #4 in mind, losing the ability to participate in reimbursement from Federal programs can shut the doors! Every risk assessment should include at least a review of the CoP. The question is would you cite any of this material when presenting to the board regarding the targeted risk assessment of the New Coding and Billing Vendor? If yes keep it in your toolbox for use in Assignment #4.
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