Things you need to know about the 3-day billing rule

by: Lauren C. Williams Jun 21, 2012

You don't have much time to prepare for CMS' three-day billing window for hospital practices which goes into effect July 1. So even if you're not sure whether your practice is wholly owned by a hospital, there are a few things you need to know.

Here’s a brief summary of points CMS addresses in its June 14 released FAQs on the three-day billing rule.

Practices owned by psychiatric hospitals and units, inpatient rehabilitation hospitals and units, long-term care hospitals, children’s hospitals and cancer hospitals are subject to the one-day billing rule instead of the three-day rule.
The three-day rule refers to calendar days and cannot be translated to 72 hours. For example, if a patient is seen at a practice at 1 a.m. Tuesday and is admitted to the owning hospital at 3 p.m. Friday, more than 72 hours have passed.
You are exempt from the three-day rule if:
- The practice and hospital are both owned by another organization; or
- The hospital owns less than 100% of the practice and shares ownership with other investors.
Physician practices that were recently acquired by a hospital are subject to the rule and must update their CMS-855B enrollment forms to reflect new ownership stake.
Hospitals are responsible for notifying practices of patient admissions and ultimately determine whether physician office services are clinically related and thus subject to the three-day rule.
Diagnostic services fall under the three-day rule even if they are unrelated to the reason for hospital admission. For example, a practice physician orders an X-ray to monitor a patient’s broken leg and the patient is later admitted for chest pains. The X-ray, even though it’s unrelated to chest pains, is subject to the rule and can’t be billed by the practice.
You can’t bill for the technical component of diagnostic imaging tests, even if you performed them, should the patient be admitted to the hospital within three days of the office visit.
Surgical services with a global period payment are subject to the rule when the surgery and outpatient surgical procedure happen within three days. Note: If the initial surgery that started the global period falls outside of three day window, it is not subject to the pay cut.
Submit the actual charge for outpatient Part B claims subject to the rule.

Visit http://tinyurl.com/bwfxt4j to read the FAQs in full.

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