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Compliance

Overview

Understanding and maintaining compliance with laws and regulations are necessary for the practice of hospital medicine. The resources below focus on many of the critical policies that impact hospital medicine and help hospitalists navigate the ever-growing and changing regulatory complexities of modern healthcare.

SHM’s Practice Management department works together with the Government Relations team to ensure hospitalist perspectives and experiences are represented and included in federal policy decisions. See more about SHM’s current advocacy efforts

 

Coding & Clinical Documentation

Coding, clinical documentation and reimbursement are all foundational concepts necessary for any hospital medicine practice. Hospitalists cannot always bill for everything they do, but they can document and code completely and accurately to ensure their work is appropriately reimbursed.

2023 Changes to the Hospitalist Evaluation and Management Codes

One-pager on the changes to the Hospital Medicine E/M Codes that go into effect January 1, 2023, including the elimination of observation codes, revisions to the inpatient codes, changes in how to bill and document for visits, and adjustments to wRVUs.

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Policy Update on 2022 Medicare Split (or Shared) Billing Rule

One-pager on recently finalized rules for split (or shared) billing of hospital visits between physicians and NPs/PAs. Updated Nov 2022.

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Utilization Management and Clinical Documentation

Document with improved accuracy and quality with SHM's Utilization Management and Clinical Documentation for Hospitalists.

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Clinical Documentation Pearls for Hospitalists

A small printable guide to help hospitalists document with consistency and clarity.

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Hospitalist Specialty Code

On April 3, 2017, the Centers for Medicare & Medicaid Services (CMS) assigned a specialty code, “C6” for providers that identify themselves as hospitalists. In a monumental step, hospitalists can now differentiate and properly benchmark their performance against other specialties, such as internal medicine and family medicine. Using this specialty code allows for more opportunities to be rewarded while simultaneously minimizing unnecessary penalties.

“This major milestone for hospital medicine demonstrates the continued growth and impact of the specialty.”
– Dea Robinson, FACMPE, Practice Management Committee Member

Due to the persistent efforts of SHM’s Board of Directors, staff and Public Policy Committee, a formal application proposing the need for a hospitalist specialty code – a code that would never have even been considered – was approved. Hospital medicine is the first medical specialty to be granted a specialty code without also having a board certification.

A provider can designate their specialty as “hospitalist” in Medicare’s provider enrollment system (Provider Enrollment, Chain and Ownership System; PECOS). Hospitalists may need to work with their credentialing team and administrators to enact this change for their Medicare enrollment.

Access PECOS

Observation Care Rules

Two-Midnight Rule

Medicare promulgated the Two-Midnight Rule in 2013 in response to the rise in number and length of observation stays. The rule is intended to provide a clear time-based threshold for when a patient should and should not be admitted as an inpatient. Any patient whose hospital stay is expected to cover at least two midnights is generally considered inpatient, while any patient who requires less than two midnights would be observation.

The Two-Midnight Rule has been highly controversial since its enforcement. In conjunction with our Government Relations department, our resources accessible below will help hospitalists understand, apply and advocate for improvements regarding observation care.

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Buprenorphine Practice Guidelines

Webinar: How to be a Hospitalist Opioid Use Disorder Champion

2020 was a record year for drug overdose deaths. The hospitalist role in providing effective care for patients with opioid use disorder (OUD) has never been more important. Recent policy changes to the X-Waiver for treating OUD have made it easier for more hospitalists to engage in this work at a critical teachable moment.

In this webinar, two physicians and one physician assistant discussed their experience in becoming OUD treatment champions. Each panelist practices in different regions of the country and shared strategies for obtaining institutional support, identifying community partners for post-discharge treatment linkage, and reducing stigma experienced by patients with OUD. Physician panelists discussed their path to Addiction Medicine Board certification, and opportunities for board certification outside of an Addiction Medicine fellowship program which are available through 2025. Instructions for how to become X-Waiver certified closed out the didactic portion of the session before an open time of Q&A with attendees.

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X-Waiver

In April 2021, the Department of Health and Human Services announced new practice guidelines regarding the prescribing of buprenorphine, a controlled medication proven to reduce withdrawal symptoms, improve mortality, and increase remission in patients with Opioid Use Disorder.  

Under these new guidelines, physicians and NPs/PAs can receive an exemption from the X-Waiver training requirements to treat up to 30 patients. 

SHM encourages all hospitalists to submit the Notification of Intent to become X-Waivered under the new practice guidelines to help ensure patients with Opioid Use Disorder can access treatment. 

Buprenorphine Practice Guidelines FAQs

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Read more about Buprenorphine Practice Guidelines and the X-Waiver