Monitoring regulatory changes

Today’s world of instant news has teams inundated with information. The volume of information that hits a revenue integrity team member’s computer screen is overwhelming. You must discern what you need to pay attention to and what is providing distraction. For example, selecting the appropriate listservs can help to distill the volume and bring into focus items of importance. In addition to listservs, there are a variety of notices that come from Medicare Administrative Contractors (MAC) as well as the Centers for Medicare & Medicaid Services (CMS). The types of common notices are as follows:

1. Federal Register notices. These notices inform the healthcare community of new published regulations.
2. CMS press releases. These notices inform the healthcare community of new programs and initiatives (e.g., new payment model demonstration projects) of the agency as well as emergency responses (e.g., hurricane response initiatives).
3. MAC notices. These notices consist of revisions to CMS manuals, deadline extensions, and other policy changes or announcements—anything from changes to MAC procedures to gain or loss of new CMS contracts, key employment change (e.g., new medical director), or any other relevant matters.

The pattern by which regulatory changes are released, once learned, can be predicted and scheduled as part of the annual work calendar. Once in cadence, the time spent reviewing the information can be reduced. Carving out time to read, analyze, and translate rules and how they relate to your facility’s operations is invaluable. Time spent monitoring regulatory changes protects the institution from payment exposures, compliance issues, and missed opportunities. In fact, understanding and monitoring regulatory changes is the cornerstone of a well-run revenue integrity team.

Listservs are considered the first line of defense in ensuring that one remains up to date on current events related to revenue cycle operations. CMS, MACs, professional societies, and consultants all offer relevant topics delivered timely to your email inbox. Skim the content for the headlines. This will help you identify those articles of interest and relevance.

Proposed and final rules published in the Federal Register are the next most important source of information. The timing of the proposed and final rules is predictable and should be scheduled with time planned to thoroughly read these documents. Yes, these documents are long and complex, but this is the best way to gain insight from the horse’s mouth. Although analysis from a consultant or trustworthy news source may prove helpful, it should not serve as a replacement for reading the Federal Register yourself. Over the years, I have gleaned priceless information from Federal Register comments that I would not have been able to report back to my employer had I not read applicable issues of the Federal Register in their entirety. No professional society, hospital association, or consultant can be expected to read the rule with the same lens you can wear as a member of the facility’s revenue integrity team. I strongly encourage this investment of time.

Medicare also offers a full catalog for providers that presents material in an easier-to-understand manner. This catalog is found electronically on the CMS website and is known as the CMS Medicare Learning Network® (MLN). According to CMS (2017), “this catalog includes MLN Matters® articles, publications and educational tools, web-based training courses, podcasts, webinars, videos, provider association partnerships, and MLN Connects.”

Lastly, look for your MAC’s interpretations of the applicable regulations you are trying to digest. Like CMS, the MAC offers documents and other materials that can generally be easier to understand than the Federal Register. Examples of the MAC materials include live webinars, computer-based training, newsletters, and podcasts. These materials are also helpful in developing headlines for the organization. Of note, sometimes the MACs interpret a CMS rule quite differently than the provider community expects. Surveillance of MAC listservs is a great way for the revenue integrity professional to protect his or her organization from unexpected consequences of regulatory changes. Visit the CMS and MAC websites to sign up for relevant listservs.

Editor's note: This article is excerpted from NAHRI’s Core Functions of Revenue Integrity, written by Valerie A. Rinkle, MPA, ACHE, Sarah Goodman, MBA, CHCAF, COC, CCP, FCS,  Terri Rinker, MT (ASCP), MHA, Anna Santoro, MBA, CCS, CCS-P, RCC, Donna Schneider, RN, MBA, CPHQ, CPC-P, CHC, CPCO, CHPC, and Angela Simmons, CPA.