Q&A: Chargemaster maintenance and price transparency
Editor's note: This Q&A is included in NAHRI's 2020 State of the Revenue Integrity Industry Report. Click here to read the full report and participate in 2020 Revenue Integrity Week activities.
The following is a question and answer session with Sarah L. Goodman, MBA, CHCAF, COC, CHRI, CCP, FCS, president/CEO of SLG, Inc., in Raleigh, North Carolina, on chargemaster maintenance and price transparency as reported in NAHRI’s 2020 State of the Revenue Integrity Industry Survey. Goodman is a NAHRI Advisory Board member.
Q. Nearly half (48%) of respondents structure their chargemaster maintenance by assigning a team to this responsibility. What should teams be aware of when maintaining their chargemaster?
A. Chargemaster teams should have representation from various areas, including ancillary departments, compliance, coding/HIM, finance, physician leadership, if possible, and of course, revenue integrity. These teams should be cognizant of the changing healthcare landscape both internally and externally—this year especially due to COVID-19—and the impact this has had or may have on chargemaster structure, pricing, charge capture, and overall compliance. Moreover, they should be positioned to take a proactive rather than reactive approach to the constant barrage of data, new code sets, and shift to a “hospital without walls” mentality. Teams should focus on policy and procedure development to describe new or temporary chargemaster services during the public health emergency, strategies to address CMS’ second round of sweeping changes released April 30, and the addition of statistical codes to the chargemaster to track services provided that are currently not separately billable. If these tracked services become eligible for reimbursement retroactively, the team will be able to easily identify the patients associated with them and can proceed accordingly.
Q. Most respondents (30%) have a chargemaster approval process that involves sending individual requests to a central person. What should this team member be aware of when approving chargemaster changes?
A. This team member should have familiarity with CPT®/HCPCS coding, UB-04 revenue coding, modifier assignment, pharmacy multipliers, facility pricing policies, and general reimbursement methodologies. Knowledge of how the charge description master (CDM) relates to the annual cost report is a definite plus.
Q. Most respondents (74%) assign HCPCS codes to all drugs and supplies if such a code exists. Is this a prudent practice? Why or why not?
A. With the advent of the -JW modifier requirements for reporting wastage of single-dose drugs and biologicals a few years ago, it is imperative that separately reimbursable drugs be HCPCS-coded and reported under UB-04 revenue code 0636 (drugs requiring detailed coding) with the appropriate units dispensed and discarded. However, non-separately payable drugs (i.e., those with status indicator of N under the OPPS) may be HCPCS-coded in the CDM but should be reported under a packaged revenue code such as 0250 (pharmacy—general) or 0258 (IV solutions), at least for Medicare. Other payers want the HCPCS and 0636 revenue code reported on all pharmaceuticals regardless of payment methodology.
Q. Most respondents (62%) use exploding charges, panel charges, or other mechanisms to ensure a single chargemaster number triggers the charging of multiple components when appropriate. What recommendations do you have for using exploding charges, etc.? How often should these charges be reviewed and updated?
A. While exploding charges and other CDM triggers can be beneficial and simplify charge capture, they can also create some billing compliance nightmares if not established and maintained appropriately. These charging mechanisms should be reviewed at least annually—or at any time when updating the chargemaster. Ensure also that there is a policy in place for crediting the entire panel or components of such panels should the services not be rendered in their entirety.
Q. Approximately 44% of respondents are not tracking who is viewing and/or downloading their public list of items and services and have no plans to do so. Should facilities track this? Why or why not?
A. The percentage of those not tracking is still surprisingly high but down 7% from last year. Thus, some of those who had no plans felt it was now important to do so. Perhaps curiosity took over or the facilities simply found a way to begin tracking in a cost-effective and efficient manner. In any event, while the collected data may not have an immediate, apparent benefit, it may prove useful during a survey or audit, or even in future marketing strategies.