DMAS has posted two new items on Nov 4, 2014 pertaining to the Nov 1 changes to how the nursing facility per diem medicaid rate will be set.
Instructions to watch the webinar are here.
The new FAQ dated 11/4/14 are here.
The rates to be used to calculate the per diem rate on Nov 1 are posted here.
Thursday, November 6, 2014
Tuesday, November 4, 2014
CMS Publishes new S&C Letter on Expansion of MDS Focused Survey: Will also verify staffing levels
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Tuesday, October 28, 2014
Revised 10/28/14 6:55 PM EST: New Clarification for Virginia Medicaid Per Diem Payments: October 27, 2014
Yesterday DMAS posted a set of FAQs that changed the rules on 'late completion' of an OBRA assessment. Here is the specific Q&A:
Q26. How does DMAS define a late assessment?
A26. If the Omnibus Budget Reconciliation Act (OBRA) quarterly assessment is not scheduled within the timelines as defined by the requirements in the Resident Assessment Instrument (RAI) manual published by CMS, the assessment shall be considered late. The nursing facility shall bill the default RUG code until a new assessment has been completed and accepted.
Assessments with Assessment Reference Dates (ARD) that do not comply with OBRA scheduling requirements are subject to default. For example, a quarterly assessment is required to have an ARD no more than 92 days after the most recent OBRA assessment’s ARD. If the provider does not open this assessment until after the last required date, then the provider will need to bill the default rate from 92 days after the most recent OBRA assessment until the next OBRA assessment’s ARD. All OBRA scheduling requirements as listed in the RAI manual apply.
Comment: Notice, you get default for the number of days that ARD is out of compliance, not for late completion or late transmission. If you have late OBRAs now that will be used to pay in November, it would be wise to set a new one now so the latest one won't be late.
I also notice they do not use the definition of "Late ARD" for a comprehensive that is more than 366 days from the ARD of the last comprehensive. They only use the 92 day timeframe.
Additionally there are some troublesome issues in this Q&A. For example, it alludes to "opening" the assessment, but they seem to mean "setting the ARD." I don't think they have finished refining this yet. It is prudent to strive for timely ARD, completion and transmission to mitigate the possibility of having to bill default. The phrase "until a new assessment has been completed and accepted" can be troublesome as well. The final implementation memo, posted in the 'resources' section of my website says this:
"The new RUG code should not be billed until the MDS assessment has been completed and accepted in the Quality Improvement and Evaluation System (QIES) Assessment Submission and Processing (ASAP) system. Once the MDS submission is transmitted and accepted, the new RUG should be billed retroactive to the Assessment Reference Date (ARD) for the MDS submission for the RUG."
So, I believe they mean this: If the ARD is late, you bill the default rate for the number of days it is late. You can't bill at all until the MDS has been accepted. I do not think they mean that there is a direct financial penalty for late 'completion' or late 'transmission.'
Additionally there are some troublesome issues in this Q&A. For example, it alludes to "opening" the assessment, but they seem to mean "setting the ARD." I don't think they have finished refining this yet. It is prudent to strive for timely ARD, completion and transmission to mitigate the possibility of having to bill default. The phrase "until a new assessment has been completed and accepted" can be troublesome as well. The final implementation memo, posted in the 'resources' section of my website says this:
"The new RUG code should not be billed until the MDS assessment has been completed and accepted in the Quality Improvement and Evaluation System (QIES) Assessment Submission and Processing (ASAP) system. Once the MDS submission is transmitted and accepted, the new RUG should be billed retroactive to the Assessment Reference Date (ARD) for the MDS submission for the RUG."
So, I believe they mean this: If the ARD is late, you bill the default rate for the number of days it is late. You can't bill at all until the MDS has been accepted. I do not think they mean that there is a direct financial penalty for late 'completion' or late 'transmission.'
Here is the link to the official document, revised yesterday:
http://www.dmas.virginia.gov/Content_atchs/pr/NF%20Price-Based%20FAQs%20as%20of%2010%2027%2014%20%282%29.pdf
I have been asking many questions to our state representatives. I do not believe they fully understand the difference between late ARD, late completion, late transmittal, etc, so I am asking for your help. If you also find that questions arise when you read the final memo and the new FAQ document, please ask DMAS at this email: NFPayment@dmas.virginia.gov.
If they hear from all of you, instead of just me, it may prove to them that they need to clarify more items.
I have been asking many questions to our state representatives. I do not believe they fully understand the difference between late ARD, late completion, late transmittal, etc, so I am asking for your help. If you also find that questions arise when you read the final memo and the new FAQ document, please ask DMAS at this email: NFPayment@dmas.virginia.gov.
If they hear from all of you, instead of just me, it may prove to them that they need to clarify more items.
Monday, October 20, 2014
A0600 Medicare Number and A030B PPS assessment Fatal Error
Below is guidance provided today (10/20/14)by CMS, from the Virginia & North Carolina RAI Managers. This question has been asked frequently since the October 1st software update, and CMS has responded to industry questions about the requirement for a Medicare number on PPS MDS assessments.
Question:
A third-party, private insurance company requires that facilities complete and submit an assessment to them for reimbursement. Since the beneficiary does not have a Health Insurance Claim Number (HICN) to enter into Item A0600B, the new edit for this item is causing a problem with our software in that the facility cannot “lock” the assessment in order to generate a RUG. What can a vendor do to assist the facility in order to generate a RUG to send to the third-party insurance company?
The answer is:
Answer:
Edit (-3571) for Item A0600B states: “If this is a PPS assessment (A0310B= [01,02,03,04,05,06,07]), then the Medicare or comparable railroad insurance number (A0600B) must be present (not [^]). Thus, the submission will be rejected if this is a PPS assessment and A0600B is equal to [^].” In effect, if an assessment is coded as a PPS assessment, it will fail edit -3571 if the HICN or comparable Railroad Insurance number is not present (left blank) in Item A0600B.
Rationale:
Assessments that are being completed for third party billing must NOT be submitted to the QIES ASAP system. Marking assessments as a PPS assessment when it is not for a Medicare part A Stay does not follow RAI coding instructions. Submitting assessments marked as PPS to CMS when a facility is not seeking payment for a Medicare part A stay, is a violation of HIPAA’s minimum necessary standard.
Vendors should work with their providers to meet their needs. How these needs are met are between the provider and the vendor, i.e., a business arrangement. A vendor is permitted (and encouraged) to add additional functionality that the free, CMS provided software, jRAVEN, does not provide.
An example of a possible vendor solution to the question above: The vendor may choose to not enforce this edit until the RUG has been generated since the assessment is for third-party insurance purposes and would not be submitted to CMS.
Thursday, October 9, 2014
Changes to 5 Star Rating System in 2015
CMS Announces Two Medicare Quality Improvement InitiativesAdministration redoubles its efforts to improve quality of post-acute care for Medicare beneficiaries
Today, the Centers for Medicare & Medicaid Services (CMS) announced two initiatives to improve the quality of post-acute care. First, the expansion and strengthening of the agency's widely-used Five Star Quality Rating System for Nursing Homes will improve consumer information about individual nursing homes' quality. Second, proposed new conditions of participation for home health agencies willmodernize Medicare's Home Health Agency Conditions of Participation to ensure safe delivery of quality care to home health patients.
"We are focused on using as many tools as are available to promote quality improvement and better outcomes for Medicare beneficiaries," said Marilyn Tavenner, CMS administrator. "Whether it is the regulations that guide provider practices or the information we provide directly to consumers, our primary goal is improving outcomes."
Nursing Home Five-Star Rating System
Beginning in 2015, CMS will implement the following improvements to the Nursing Home Five Star Quality Rating System:
- Nationwide Focused Survey Inspections:Effective January 2015, CMS and states will implement focused survey inspections nationwide for a sample of nursing homes to enable better verification of both the staffing and quality measure information that is part of theFive-Star Quality Rating System. In Fiscal Year (FY 2014), CMS piloted special surveys of nursing homes that focused on investigating the coding of the Minimum Data Set (MDS), which are based on resident assessments and are used in the quality measures.
- Payroll-Based Staffing Reporting:CMS will implement a quarterly electronic reporting system that is auditable back to payrolls to verify staffing information. This new system will increase accuracy and timeliness of data, and allow for the calculation of quality measures for staff turnover, retention, types of staffing, and levels of different types of staffing. Implementation will be improved by funding provided in the recently enacted, bipartisan Improving Medicare Post-Acute Care Transformation Act (IMPACT) of 2014.
- Additional Quality Measures:CMS will increase both the number and type of quality measures used in theFive-Star Quality Rating System. The first additional measure, starting January 2015, will be the extent to which antipsychotic medications are in use. Future additional measures will include claims-based data on re-hospitalization and community discharge rates.
- Timely and Complete Inspection Data:CMS will also strengthen requirements to ensure that States maintain a user-friendly website and complete inspections of nursing homes in a timely and accurate manner for inclusion in the rating system.
- Improved Scoring Methodology:In 2015, CMS will revise the scoring methodology by which we calculate each facility's quality measure rating, which is used to calculate the overallFive Starrating. We also note that sources independent of self-reporting by nursing homes already are weighted higher than self-reported components in the scoring methodology.
"Nursing homes are working to improve their quality, and we are improving how we measure that quality," said Patrick Conway, M.D., deputy administrator for innovation and quality and CMS chief medical officer. "We believe the improvements we are making to the Five Star system will add confidence that the reported improvements are genuine, are sustained, and are benefiting residents."
Home Health Conditions of Participation
The proposed Home Health Conditions of Participation would improve the quality of home health services for Medicare and Medicaid beneficiaries by strengthening patient rights and improving communication that focuses on patient wellbeing. Currently there are more than 5 million people with Medicare and Medicaid benefits that receive home health care services each year from approximately 12,500 Medicare-certified home health agencies.
The proposed regulation, to be displayed Monday, October 6, at the Federal Register, would modernize the home health regulations for the first time since 1989 with a focus on patient-centered, well-coordinated care. Elements in the regulation include expansion of patient rights requirements; refocusing of the patient assessment on physical, mental, emotional, and psychosocial conditions; improved communication systems and requirements for a data-driven quality assessment; and performance improvement (QAPI) program.
For more information, visit: http://www.cms.gov/Center/Provider-Type/Home-Health-Agency-HHA-Center.html.
Friday, September 19, 2014
RAI MANUAL ERRATA ON THE WAY & Virginia specific guidance from State RAI Manager
From: Bullard, Priscilla (VDH)
Sent: Friday, September 19, 2014 10:11 AM
To: Bullard, Priscilla (VDH)
Subject: RAI manual updates and CCC information
Sent: Friday, September 19, 2014 10:11 AM
To: Bullard, Priscilla (VDH)
Subject: RAI manual updates and CCC information
Dear Colleagues,
As you know, CMS has released the October 2014 RAI manual. There are some known issues with missing parts to this manual, as well as some textual errors. CMS will be sending out an errata or updated manual, which will be at the same site: http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/NursingHomeQualityInits/MDS30RAIManual.html
If you print your manual out, I recommend waiting until the clarifications are released by CMS. Some of the issues with the current release include missing item sets, incorrect or unclear text examples, and conflicting instructions.
Please realize there are changes to the actual MDS items. There is a new field, A1900, which captures the original admission date for the resident. CMS will be releasing further information for this field as the terms used in the new manual are not defined clearly. If you have not liaised with your software company regarding updates, please do so- any assessments with an ARD of 10/1/14 or later need to use the new item sets. I recommend that providers be able to manually enter data into A1900, as I have heard anecdotally that some software vendors are pre-populating this field from A1600 of the prior assessment. Under some circumstances, this date could be incorrect and the provider needs the ability to enter correct data.
I will be posting a webinar about the updates on the VDH website after the manual is finalized, and will email the link when it is posted.
Lastly, I wanted to address the questions about Medicaid information on the MDS for any Commonwealth Coordinated Care(CCC) residents. DMAS has confirmed the following:
· For CCC residents, A0700 will continue to have the traditional Medicaid number for the resident, not the CCC number
· For CCC residents, S9100 is coded as managed care for the pay source on the ARD, and with the resident’s original Medicaid start date
· For traditional Medicaid residents, A0700 and S9100 will be completed with the resident’s regular Medicaid data(number and start date). See pages A-10 and A-11 of the RAI manual
· For residents with other pay sources, A0700 will be completed as per the RAI manual
· For residents with other pay sources, S9100 will show the resident’s pay source on the ARD and 1/1/1950 will be used as a start date so that the assessment can be locked
Cil Bullard RN,CPC | Virginia RAI/OASIS Coordinator | Training Division | Office of Licensure and Certification| Virginia Department of Health | 9960 Mayland Dr Suite 401 |Henrico, VA 23233-1485| ( 804-367-2141 7 804-527-4502 priscilla.bullard@vdh.virginia.gov
Friday, September 5, 2014
SNF Stay is protected even when hospitals rebill Part B for a medically unnecessary stay
From the Center for Medicare Advocacy
Hospitals May Begin Rebilling Medicare Patients Who Were Hospitalized After October 1, 2013
Medicare patients need to be aware that if they were hospitalized after October 1, 2013, hospitals may be contacting them about their bills.
Final rules that were published in August 2013 and became effective October 1, 2013 created a new regulatory provision, 42 C.F.R. 414.5, "Hospital services paid under Medicare Part B when a Part A hospital inpatient claim is denied because the inpatient admission was not reasonable and necessary, but hospital outpatient services would have been reasonable and necessary in treating the beneficiary."[1] Section 414.5(a) authorizes a hospital to rebill Part B if a claim under Part A is denied or, on its own initiative, if the hospital determinesafter the patient is discharged that the patient's hospital stay should have been billed as outpatient rather than as inpatient.[2]
Under the new rebilling option, CMS gives a hospital only one year after providing services to a patient to change its decision about the patient's inpatient status and to submit a bill to Medicare under Part B instead of Part A. The one-year deadline is approaching for services provided on or after October 1, 2013, the effective date of the regulations.
If a hospital rebills Medicare under Part B, it must refund the Part A deductible to the patient (or supplemental insurer) and it may bill the patient both for copayments for services provided under Part B and for medications.[3]
If a hospital exercises its rebilling option, patients may want to submit the medication bill to their Part D plan and request that the plan pay the pharmacy bill as an out-of-network pharmacy, since the hospital pharmacy is unlikely to be in the patients' pharmacy network.[4]
Part A-Covered SNF Stay Is Protected Even When the Hospital Rebills Medicare Part B
If a hospital exercises its rebilling option and submits a Part B claim for a patient following the patient's discharge from the hospital, the patient retains inpatient status for purposes of Medicare Part A coverage of the subsequent SNF stay. CMS explicitly provides in the preamble to the final rules:
CMS rejects commenters' suggestions that patients be provided with an additional standardized notice or a Frequently Asked Questions sheet, or that information be added to the Important Message from Medicare (IM) form to alert patients at the time of their inpatient admission to an acute care hospital that their status at the hospital might be changed during, or after, their hospital stay. CMS describes such notices as "likely [to] create undue confusion and concern for beneficiaries"[7] and says it will engage in an educational campaign for beneficiaries.
CMS writes that it will provide information in its publication "Are You a Hospital Inpatient or Outpatient? If You Have Medicare – Ask!" but the May 2014 revision does not explain that the hospital may change a patient's status after discharge.[8] CMS also writes that it will add new messages in the Medicare Summary Notice, but the Center for Medicare Advocacy did not find a new code in the updated list of MSN codes released on July 24, 2014.[9] CMS'sMedicare & You briefly discusses observation status.[10]
CMS Offers Hospitals Settlement of Short Inpatient Claims Before October 1, 2013
Hospitals have been appealing denials of inpatient claims. On August 29, 2014, CMS offered "an administrative agreement to any hospital willing to withdraw their pending appeals in exchange for timely partial payment (68% of the net allowable amount)."[11] CMS defines eligible claims under the settlement offer as:
Hospitals choosing to settle pending appeals with CMS may "not seek additional payment from any Medicare beneficiary or collect any deductible or coinsurance amount regarding any claim resolved through this Agreement that is not subject to a repayment plan existing as of the effective date of this Agreement," but they "may retain any Medicare beneficiary deductible or coinsurance amounts already paid as of the effective date of this Agreement."[12]
Medicare patients will not hear from hospitals that settle with CMS on the terms offered. The hospitals will retain the inpatient deductibles that patients paid.
Conclusion
October 1, 2013 is an important date for Medicare patients' hospitalizations.
Medicare beneficiaries may receive letters from hospitals about their hospitalizations after October 1, 2013 if hospitals decide to withdraw their Part A charges and, instead, bill Medicare Part B and bill the patients for Part B copayments and medications. Patients' entitlement to Part A coverage of their skilled nursing facility care is not affected.
Medicare beneficiaries who were hospitalized before October 1, 2013 may hear nothing from their hospitals, though the hospitals may either accept the settlement terms offered by CMS or continue to pursue their administrative appeals. These patients' SNF coverage is also unaffected.
Hospitals May Begin Rebilling Medicare Patients Who Were Hospitalized After October 1, 2013
Medicare patients need to be aware that if they were hospitalized after October 1, 2013, hospitals may be contacting them about their bills.
Final rules that were published in August 2013 and became effective October 1, 2013 created a new regulatory provision, 42 C.F.R. 414.5, "Hospital services paid under Medicare Part B when a Part A hospital inpatient claim is denied because the inpatient admission was not reasonable and necessary, but hospital outpatient services would have been reasonable and necessary in treating the beneficiary."[1] Section 414.5(a) authorizes a hospital to rebill Part B if a claim under Part A is denied or, on its own initiative, if the hospital determinesafter the patient is discharged that the patient's hospital stay should have been billed as outpatient rather than as inpatient.[2]
Under the new rebilling option, CMS gives a hospital only one year after providing services to a patient to change its decision about the patient's inpatient status and to submit a bill to Medicare under Part B instead of Part A. The one-year deadline is approaching for services provided on or after October 1, 2013, the effective date of the regulations.
If a hospital rebills Medicare under Part B, it must refund the Part A deductible to the patient (or supplemental insurer) and it may bill the patient both for copayments for services provided under Part B and for medications.[3]
If a hospital exercises its rebilling option, patients may want to submit the medication bill to their Part D plan and request that the plan pay the pharmacy bill as an out-of-network pharmacy, since the hospital pharmacy is unlikely to be in the patients' pharmacy network.[4]
Part A-Covered SNF Stay Is Protected Even When the Hospital Rebills Medicare Part B
If a hospital exercises its rebilling option and submits a Part B claim for a patient following the patient's discharge from the hospital, the patient retains inpatient status for purposes of Medicare Part A coverage of the subsequent SNF stay. CMS explicitly provides in the preamble to the final rules:
The status of the beneficiaries themselves does not change from inpatient to outpatient under the Part B inpatient billing policy. Therefore, even if the admission itself is determined to be not medically necessary under this policy, the beneficiary would still be considered a hospital inpatient for the duration of the stay – which, if it occurs for the appropriate duration, would comprise a "qualifying" stay for SNF benefit purposes so long as the care provided during the stay meets the broad definition of medical necessity above [referring to the Medicare Benefit Policy Manual, Chapter 8, §20.1].[5]
CMS reiterates this point later in the preamble:
[W]hen the inpatient hospital stay is paid under Part B, the hospital stay remains inpatient from the time of admission and may continue to count towards qualification for skilled nursing facility coverage, and the beneficiary is liable for the Part B inpatient charges.[6]
CMS Notice to Medicare PatientsCMS rejects commenters' suggestions that patients be provided with an additional standardized notice or a Frequently Asked Questions sheet, or that information be added to the Important Message from Medicare (IM) form to alert patients at the time of their inpatient admission to an acute care hospital that their status at the hospital might be changed during, or after, their hospital stay. CMS describes such notices as "likely [to] create undue confusion and concern for beneficiaries"[7] and says it will engage in an educational campaign for beneficiaries.
CMS writes that it will provide information in its publication "Are You a Hospital Inpatient or Outpatient? If You Have Medicare – Ask!" but the May 2014 revision does not explain that the hospital may change a patient's status after discharge.[8] CMS also writes that it will add new messages in the Medicare Summary Notice, but the Center for Medicare Advocacy did not find a new code in the updated list of MSN codes released on July 24, 2014.[9] CMS'sMedicare & You briefly discusses observation status.[10]
CMS Offers Hospitals Settlement of Short Inpatient Claims Before October 1, 2013
Hospitals have been appealing denials of inpatient claims. On August 29, 2014, CMS offered "an administrative agreement to any hospital willing to withdraw their pending appeals in exchange for timely partial payment (68% of the net allowable amount)."[11] CMS defines eligible claims under the settlement offer as:
currently pending appeals of inpatient-status claim denials by Medicare contractors on the basis that services may have been reasonable and necessary, but treatment on an inpatient basis was not, with dates of admission prior to October 1, 2013, and where the patient was not a Part C [managed care] enrollee.
Hospitals may accept the settlement for some inpatient claims while continuing to pursue other claims through the administrative process.Hospitals choosing to settle pending appeals with CMS may "not seek additional payment from any Medicare beneficiary or collect any deductible or coinsurance amount regarding any claim resolved through this Agreement that is not subject to a repayment plan existing as of the effective date of this Agreement," but they "may retain any Medicare beneficiary deductible or coinsurance amounts already paid as of the effective date of this Agreement."[12]
Medicare patients will not hear from hospitals that settle with CMS on the terms offered. The hospitals will retain the inpatient deductibles that patients paid.
Conclusion
October 1, 2013 is an important date for Medicare patients' hospitalizations.
Medicare beneficiaries may receive letters from hospitals about their hospitalizations after October 1, 2013 if hospitals decide to withdraw their Part A charges and, instead, bill Medicare Part B and bill the patients for Part B copayments and medications. Patients' entitlement to Part A coverage of their skilled nursing facility care is not affected.
Medicare beneficiaries who were hospitalized before October 1, 2013 may hear nothing from their hospitals, though the hospitals may either accept the settlement terms offered by CMS or continue to pursue their administrative appeals. These patients' SNF coverage is also unaffected.
[1] 78 Fed. Reg. 50495 (Aug. 19, 2013). See Center for Medicare Advocacy, "Observation Status: New Final Rules from CMS Do Not Help Medicare Beneficiaries" (CMA Alert, Aug. 29, 2013),http://www.medicareadvocacy.org/observation-status-new-final-rules-from-cms-do-not-help-medicare-beneficiaries/.[2] The rebilling option was one of two changes to federal regulations that the Centers for Medicare & Medicaid Services (CMS) made in 2013, in part to address the issue of Observation Status. Observation Status is the classification of hospitalized patients as outpatients, not inpatients, even though the care they receive in the hospital may be identical.[2] If patients are outpatients or are said to be in Observation Status, Medicare Part A will not pay for their post-acute care in a skilled nursing facility (SNF). The other change created in 2013 was the two-midnight rule. Under this time-based analysis, physicians admit patients to inpatient status if they believe the patients will be in the hospital for two or more midnights.[3] 78 Fed. Reg., 50918, 50930-50931 (coordination of benefits with supplemental insurers).[4] See CMA, "Submitting Claims to Part D for Prescription Drugs Administered in a Hospital During an Observation Status Stay" (Weekly Alert, May 1, 2014), at http://www.medicareadvocacy.org/submitting-claims-to-part-d-for-prescription-drugs-administered-in-the-hospital-during-an-observation-status-stay/.[5] 78 Fed. Reg. 50921. The Medicare Benefit Policy Manual, Ch. 8, §20.1, states that medical necessity for a hospital stay will be presumed and that, “The intermediary will rule the stay unnecessary only when hospitalization for 3 days represents a substantial departure from normal medical practice.” http://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c08.pdf. Scroll down to page 8 for §20.1. http://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R2877CP.pdf
[6] 78 Fed. Reg., 50934.[7] 78 Fed. Reg., 50919.[8] https://www.medicare.gov/Pubs/pdf/11435.pdf. [9] 78 Fed. Reg. 50919. MSN Codes, https://www.cms.gov/Medicare/Medicare-General-Information/MSN/index.html?redirect=/MSN/.[10] http://www.medicare.gov/Pubs/pdf/10050.pdf, see pages 32 and 97.[11] CMS, Inpatient Hospital Reviews," http://www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/Medical-Review/InpatientHospitalReviews.html. [12] Administrative Agreement, ¶8, available in the Downloads section," http://www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/Medical-Review/InpatientHospitalReviews.html.
[6] 78 Fed. Reg., 50934.[7] 78 Fed. Reg., 50919.[8] https://www.medicare.gov/Pubs/pdf/11435.pdf. [9] 78 Fed. Reg. 50919. MSN Codes, https://www.cms.gov/Medicare/Medicare-General-Information/MSN/index.html?redirect=/MSN/.[10] http://www.medicare.gov/Pubs/pdf/10050.pdf, see pages 32 and 97.[11] CMS, Inpatient Hospital Reviews," http://www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/Medical-Review/InpatientHospitalReviews.html. [12] Administrative Agreement, ¶8, available in the Downloads section," http://www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/Medical-Review/InpatientHospitalReviews.html.
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