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A physician must concur with the decision and document this with an observation order in the medical record.
Thechangeismadebeforethepatient is discharged and no claim has been submitted.
The patient should be informed.
For example, if our asthmatic patient had been admitted to the hospital as an inpatient, and sev­eral hours later on utilization review (UR) had been found to not meet inpatient criteria, the case manager would have brought the issue to the UR committee for their review and input. If UR agreed that outpatient services would be more appropriate, the admitting physician would be queried and if she or he concurred an order would be written for placing the patient in observation. Other criteria noted earlier would need to be met and condition code 44 would be added to the outpatient claim form prior to billing.
If all of the above conditions are satisfied, an outpatient, rather than an inpatient, claim is sub­mitted with condition code 44 reported in one of the form locators in fields 24–30 on the UB-04 claim form.
8
If this condition code 44 situation does occur it is important to remember that the counting of observation hours starts only after the observation order is written. The charges incurred before this conversion may be reported under revenue code 760 or 761.
Other implications of utilizing observation rather than inpatient status include a higher out­of-pocket cost for the patient as they will incur co­pays for outpatient services and the potential loss of a three-day qualifying inpatient stay for skilled­nursing facility coverage. For example, as an inpa­tient our asthmatic might have had nearly full coverage. However when classified as observation the patient is now responsible for their outpatient deductible and any co-insurance.
Back-end billing processes related to obser­vation reimbursement include the posting of payments, monitoring, and follow-up on denied claims. Not all payers document their policies and sometimes denials occur for unan ticipated reasons. It is important that someone monitors payer notification statements to ensure billed charges are reimbursed appropriately.
Facility Observation Reimbursement
After a payer receives the hospitals electronically submitted claim for observation payment, it will be processed or adjudicated and, if all require­ments are met, a payment will be issued.
Medicare uses a software claims editor, called the Integrated Outpatient Code Editor (I/OCE), which will determine if observation payment cri­teria are met and the claim should be paid. In this way, coders do not have to determine if an observation case meets specific criteria in order to code it, the software does this for them. The I/OCE reviewsthesubmittedclaimanddetermines the appropriate reimbursement based on the OPPS rules and the specific Ambulatory Payment Classi­fication (APC) that the submitted CPT and HCPCS codes map to (APCs are the outpatient counterpart to inpatient diagnosis-related groups [DRGs], and each has a designated payment rate).
CMS has designated observation services as a Comprehensive APC or C-APC. They are called comprehensive APCs because observation and the ED or clinic visit or direct referral that preceded it, as well as the vast majority of ancillary studies and treatments, are not reimbursed separately but rather in a single payment for the combination of these multiple services. For example, our asthmatic patient received a 99285 ED service, followed by 8 hours of observation. (Table 63.3) On the UB 04 the facility would report 99285 and 8 units of G0378. The Medicare I/OCE converts those two codes to C-APC 8011, resulting in a single pay­ment for both services to the hospital. Additionally, as a Comprehensive APC the nebulizer treatments as well as typical X-rays and other medications are packaged into the single payment (Table 63.4).
Payment methods for observation vary greatly by payer; the payment may be prospective, such as under Medicares OPPS rules, hourly, tiered based on blocks of hours, or a case rate. The approximate payment for Medicare observation is $2174 for C-APC 8011.
So, for our asthmatic patient who was initially charged as a 99285 ED visit with reimbursement of $486, with the addition of the 10 units/hours of G0378 the patient now is categorized as Observa­tion, which moves the visit to C-APC 8011 and reimbursement of $2174, representing a roughly $1800 increase.
Hospital Coding and Reimbursement
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If observation criteria are not met, the hos-
pitals payment will be based on the service that preceded it – an ED or clinic visit or a direct referral (reported with HCPCS code, G0379).
Most, but not all, commercial payers now recognize and reimburse hospitals for medically necessary observation care. If observation pay­ment policy information is not addressed in the hospitals contract with the payer, the information may be located on the payers website or in a policy manual. If not found, it will be important for someone at the hospital to query the payer to determine if the observation service is reimbursed and if so, exactly how the payer expects it to be reported. As with all services, it is wise to review payment statements to watch for denials: if all observation paymen t rules and criteria were met the denial should be appealed.
Compliance Oversight for Observation Services
Recovery Audit Contractors (RACs) and other Medicare contractors, and even private payers,
are intensely scrutinizing one-day inpatient stays and use of observation services. Observation has also been identified as an issue of concern in the Office of Inspector Generals (OIGs) annual work-plan. For these reasons, and because it is a best practice, hospitals should have written pol­icies and procedures addressing the clinical and revenue cycle aspects of observation services.
These policies should address observation
eligibility criteria, medical necessity, and known observation risk areas – physician orders, docu­mentation requirements, physician presence, observation timing issues, standing orders for observation, and excessive lengths of observa­tion over 48 hours. Policies should be based on, and consistent with, internal hospital pol­icies, joint commission standards, state licensure requirements, as well as the Medicare and Medicaid guidelines applicable to the hospital’s geographic area.
Observation should be one of the areas moni­tored under the hospitals compliance plan. Peri­odic reviews of policies and audits of observation encounters will help identify concerns and oppor­tunities for improvement, and also demonstrate the hospitals commitment to compliance. It is important that someone at the hospital monitors regulatory changes and updates as applicable to observation. This would include CMSs OPPS rules; Medicare Transmittals related to observa­tion; commercial payer, Medicare, and Medicaid website; and commercial payer bulletins. If rele­vant information is identified it should be com­municated internally, added to policies and procedures, and applied to observation revenue cycle practices.
Table 63.3 Typical Medicare Facility Reimbursement Rates
Code APC Reimbursement
99284 5024 $326.99
99285 5025 $486.04
99291 5041 $666.27
G0463 5012 $102.12
$
Source: 2016 OPPS Final Rule
Table 63.4 Medicare Observation Comprehensive APC and Reimbursement
Observation APC and Descriptor
Criteria for Medicare Observation Reimbursement Reimbursement
C-APC 8011 – Comprehensive Observation Services
Requires at least 8 units of HCPCS code G0378 in addition to 99281–99285, 99291, G0380–G0384, or G0463 on the same day or the day prior.
$2174.14
Source: Medicare Claims Processing Manual; Observation Services
Candace E. Shaeffer and Michael A. Granovsky
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References
1. How Nurses Can Impact the Revenue Cycle. HFMA–The Business of Caring, pp.12–13, August, 2007.
2. www.cms.gov/Medicare/ Medicare-Fee-for-Service­Payment/ HospitalOutpatientPPS/ Downloads/Hospital­Outpatient-Therapeutic­Services.pdf (Accessed February 19, 2016)
3. Federal Register, 42 CFR, CMS-1633-FC; CMS Vol. 80,
No. 219 November 13, 2015, OPPS Final Rule CY 2016, pp.
4. Medicare Claims Processing Manual 100-04, Chapter 4, Section 290.1 – Observation Services Overview, December 18, 2015 .
5. Medicare Claims Processing Manual 100-04, Chapter 4, Section 290.4.3 – Separate andPackagedPayment for Observation Services, December 18,
2015.
6. Medicare Claims Processing Manual 100-04, Transmittal 1760, Section 290.2.2, July 6,
2009.
7. Medicare Claims Processing Manual 100-04, Chapter 4, Section 290.2.2 – Reporting Hours of Observation, December 18, 2015.
8. Medicare Claims Processing Manual 100-04, Chapter 1, Section 50.3.2 – Policy and Billing Instructions for Condition Code 44, May 8,
2015.
Hospital Coding and Reimbursement
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Subpart VB
Chapter
64
Financial – Case Management
Determining the Correct Status
BK Kizziar, RN-BC, CCM
Consider the various portals through which patients may enter an acute care hospital. The most common and best known is the Emergency Department. There are also direct admissions from commu nity physician offices. Patients may also be transferred from a lower-level facility to the hospital. Or a hospital-to-hospital transfer may occur. Each of these portals are critical areas for identifying if the patient actually requires an inpatient hospitalization level of care. Often, the admitting physician does not have sufficient clin­ical information to make the final judgment. However, it may be obvious that the patient does require some level of medical care and further information is required in order to make the determination as to what level of care that might be. In acute care hospitals there are two categories for patients entering through these portals: Inpa- tient and Observation.
Inpatient status is given to a patient who requires constant clinical monitoring by licensed professional staff including physicians, nursing, and other care providers. Most hospitals utilize a standardized set of criter ia that was developed to assist in the determination of a level of care. The criteria, available from several commercial com­panies, consists of objective clinical findings and treatments appropriate with the condition and diagnosis. The admission criteria are commonly known as Severity of Illness (SI) and includes all of the appropriate levels of care for the condition. During the physicians evaluation of a patient to determine level of care several initial criteria are considered. The criteria are set forth by the
Centers for Medicare and Medicaid Services (CMS) and include:
1–3
1. The severity of the signs and symptoms
exhibited by the patient,
2. The medical predictability of something
adverse happening to the patient,
3. The need for diagnostic studies, acute care level monitoring, medical management, etc.,
4. All available treatment settings and options.
Should a patient not meet the initial screening criteria for an inpatient status but continue s to require a significant level of clinical monitoring, the patient may be placed in an Observation status.
Observation is an outpatient designation in
which services are provided including the use of a bed, at least periodic monitoring by nursing and other staff, and necessary treatments that are rea­sonable and necessary to evaluate and treat the patients condition or determine the need for an inpatient designation and stay. Observation care is rendered in the hospital although classified as outpatient services. It is intended for short-term monitoring, generally less than 48 hours for Medicare patients and 23 hours for managed care patients.
This chapter will speak specifically to Medi-
care reimbursement criteria as managed co m­panies negotiate various reimbursement systems with their contracting providers. Documentation by the physician is critical in establishing this level of classification. A physicians order must specify Observation Statusand must be signed and dated by the admitting physician. When the patient has been in Observation Status for 23 hours, physician documentation in the progress notes must include the need to continue observa­tion with a plan for discharge within the next 12–24 hours or the need to convert the patient to an Inpatient Status, documenting the medical necessity for admission or the medical stability of the patient allowing for discharge and a plan for follow-up services a indicated.
Observationis a payment category and not
an indication of the level of services a patient requires. Should the hospital determine after
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admission that the patient did not require an acute level of care there are two options for cor­recting the status of Medicare beneficiaries. One is known as a Condition Code 44.
4
The other is
Provider Liable.
Transmittal 299 Change Request 3444 (Condi-
tion Code 44) allows the hospital to change a
patient status from Inpatient to Observation pro­vided that four criteria are met:
1. The change in patient status from Inpatient to Outpatient/Observation is made prior to discharge or release while the individual is still a patient of the hospital;
2. The hospital has not submitte d a claim to CMS for any of the time the patient has spent receiving hospital services;
3. A physician concurs with the utilization review committees decision; and
4. The physicians concurrence with the utilization review committees decision is documented in the patients medical records.
The entire episode of care should be treated as though an inpatient admission never took place and should be billed as an outpatient episode of care.
Provider Liable is submitted on a UB-04 claim
form indicating the provider is liable for the inpatient admission if the determination that the patient did not meet acute level of care criteria is made after the discharge of the patient.
When a hospital determines that a Medicare
beneficiary does not need to be admitted or no
longer requires inpatient care, the hospital must notify the beneficiary of this determination. The notification is called a Hospital Issue Notice of
Non-Coverage (HINN) or a Medicare Advantage Notice of Discharge and Medicare Appeal Rights (NODMAR). If the beneficiary chooses to be
admitted or remain in the hospital following this notification, the hospital may charge the benefi­ciary, rather than Medicare, for the stay. Only the continued stay HINN must be reviewed by the Medicare fiduciary prior to delivery to the patient.
An Advance Beneficiary Notice (ABN) is given
to a Medicare beneficiary when it is anticipated that the outpatient/observation treatment, care, or services will not be covered by Medicare. The patient must make the decision to forego the intervention or to assume financial responsibility for the cost. This situation is seen typically in the Emergency Department. A patient presents with a condition that does not meet either Inpatient or Observation criteria. However, the patient desires to be admitted and the physician is willing to admit the patient. The patient must be made aware that Medicare will not fund the admission and should the patient be admitted will be expected to pay for all hospital services. If the patient is in Observation status and the physician wishes to change the status to Inpatient although the patient does not meet inpatient criteria, a Pre-Admission Advanced Beneficiary Notice (PAABN) must be issued to the patient indicating that the patient will be financially responsible for
Table 64.1 Beneficiary Notices
Type of Notice Attending or QIO*
Concurrence
Patient Liability Begins
Preadmission or Admission HINN
No Point at which patient enters hospital after receipt of notice is
received. However, to hold a patient liable for charges on the day of admission, the notice must be issued no later than 3 p.m. on the day of admission. If the notice is issued after 3 p.m. the patient is liable beginning the following day.
Hospital requested review
Yes Notification that patient does not qualify for continued stay but the
physician disagrees and wishes the patient to remain in the hospital. The HRR notifies the patient that the hospital is asking the QIO to review the case and make a determination whether the patient meets clinical criteria to remain in the hospital.
HINN-11 Yes Noncovered service during covered stay.
HINN-12 Yes Noncovered continued stay. Includes statement from Business
Office estimating the cost to the patient of a continued stay.
* QIO quality improvement organization
Determining the Correct Status
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all hospital services. In all instances of ABN/ PAABN issuances, the patient signature on the form is not required. There must, however, be evidence that the patient was informed as verified by witness signatures on the ABN forms. Claims are submitted with an indication that an ABN was given. (See Table 64.1.)
Medicare has contracted with private auditing firms to review discharged files to determine if patients are classified incorrectly. These auditors, known as Recovery Audit Contractors (RAC), review randomly selected discharged charts. Admissions determined to have been inappropriately classified as Inpatient are charged the amount that was paid by Medicare for the inpatient claim. Hospitals may also be fined for continued misclassification. The RACs are reimbursed for their services through a contingency agreement in which they receive a por­tion of the monies recouped.
Medicare Administrative Contractors (MACs)
were put into place to consolidate Medicare Part
A and Part B claims processing. The MACs will also compare hospital and physician claims to ensure continuity in billing practices.
The quality of care and treatment of the patient should be the same whether the admission is classified as Inpatient or Observation. The dif­ference is strictly a cost issue. This is an important consideration for patients, hospitals and payers. When admitted under Observation the patient becomes financially responsible for the co-pays associated with their payer requirements. The exact amount varies with the service provided and the payer benefits. Patients may be respon­sible for more than one co-payment. If the patients needs are best met in the acute care setting as an Inpatient, the co-pay req uirement may be significantly different and deductibles will play a role. However, if after discharge from an acute care inpatient stay the admission was deemed inappropriate, the hospital could be responsible for the entire cost of the stay.
References
1. Centers for Medicaid and Medicare Services (CMS) https://www.cms.gov/ Regulations-and-Guidance/ Guidance/Transmittals/ downloads/R1374CP.pdf (Accessed April 2016)
2. Hospital Inpatient Admission Order and Certification https:// www.cms.gov/Medicare/ Medicare-Fee-for-Service­Payment/AcuteInpatientPPS/
Downloads/IP-Certification­and-Order-09-05-13.pdf (Accessed April 2016)
3. Final Comments for Acute Inpatient Services versus Observation (Outpatient) Services (Hosp-001) DL322. https://downloads.cms.gov/ medicare-coverage-database/ lcd_attachments/32222_1/ DL32222_HOSP001_Final Comments.pdfA (Accessed April 2016)
4. Clarification of Medicare Payment Policy When Inpatient Admission is Determined Not to be Medically Necessary, Including the Use of Condition Code 44: Inpatient Admission Changed to OutpatientTransmittal #: R299CP https://www.cms.gov/ Outreach-and-Education/ Medicare-Learning-Network­MLN/MLNMattersArticles/ downloads/SE0622.pdf (Accessed April 2016)
BK Kizziar
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Subpart VB
Chapter
65
Financial – Case Management
Case Management: Care Coordination
Nancy E. Skinner, RN-BC, CCM
Observational Status: Care Coordination Through Each Transition of Care
When establishment of the medical necessity and appropriateness of care based on intensity of ser­vices and severity of illness fails to meet criteria for admission to an acute care facility, medical management and the consistent monitoring of the patients health status may be provided as an outpatient service. Deemed observational status, these services are generally utilized to gain add­itional information regarding the acuity, signifi­cance, and/or potential impact of presenting symptoms or to provide continued care or inter­ventions during a prolonged recovery following an outpatient procedure.
1
Any decision regarding appropriate patient status is based on established criteria, supported by specific and documented clinical rationale, and follows a signed and dated physician order. Deter­minations regarding the appropriateness of inpa­tient admission or observational status must be consistent with that physician order, the medical interventions or management to be provided, and the established medical necessity and appropriate­ness of those services.
Although the hospital utilization review com­mittee and utilization management plan is defined in the hospital Condition of Participation (CoP), the process of adhering to that Plan and following the criteria that supports that Plan is a vital func­tion of the hospital case manager or utilization manager. These health care professionals (HCP) are charged with coordination of each step within the process in order to facilitate effective utilization review and advance appropriate reimbursement for provided services. This is a role that should not be considered to be intermittent or cursory. To be successful, utilization managers should be
available within most facilities at least 16 hours each day, every day of the year.
Although observational status is billed as an outpatient service, the quality of provided care is mandated to be the same whether the patient is admitted to the acute care facility or determined to be appropriate for outpatient observation. In March 2011, the U.S. Department of Health and Human Services released its National Strategy for Quality Improvement in Health Care (National Quality Strategy). The strategy presents three aims for the health care system:
Better Care: Improve the overall quality, by
making health care more patient-centered,
reliable, accessible, and safe.
Healthy People and Communities: Improve
the health of the U.S. population by
supporting proven interventions to address
behavioral, social, and environmental
determinants of health in addition to
delivering higher-quality care.
Affordable Care: Reduce the cost of quality
health care for individuals, families,
employers, and government.
2
The six priorities identified to support these aims include:
Making care safer by reducing harm caused in
the delivery of care.
Ensuring that each person and family are
engaged as partners in their care.
Promoting effective communication and
coordination of care.
Supporting better health in communities.
Prevention and treatment of the leading
causes of mortality.
Making quality care more affordable for
individuals, families, employers, and
governments by developing and spreading
new health care delivery models.
3
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As todays health care facilities and providers look to following these strategies and to provide care that is safe, timely, effective, efficient, equitable and patient-centered,the focus on quality of care, cost of provided services and patient satisfaction has never been higher.
4
To achieve this delicate balance, many hospitals have established specific protocols that are designed to address the efficient movement of patients to an appropriate level of care. These steps include a focus on gaining physician direction regardingthe appropriate level of patient care based on a comprehensive assessment of the patients history and physical exam, any risk factors that are present or probable due to the patientscondition, and the care required to address patient-specific continuing needs. Additionally, the physician must document the order to provide observational care and confirmation that similar criteria is utilized for all patients regardless of payer.
While each step in the utilization review pro­cess is generally well scripted and supported by established criteria, the process that encourages patient/family engagement in their care and facili­tates an efficient and timely transition to the next level of care is often fragmented and haphazard. Patients sometimes move from one environment or provider to another with little advocacy, no established transitional care plan, and absolutely no idea that it should not be that way. We treat em a nd street em.We diagnosis and adios and rarely consider affecting an appropriate tran­sition of care. In many instances, this lack of care continuity may negatively impact the goals we desire for our patients and the goals our patients have established for themselves.
To be more successful in facilitating enhanced patient engagement and promoting effective com­munication across all levels of care, it is vital that the role of the case manager is not limited to utiliza­tion review. Case management is defined by the Case Management Society of America (CMSA) as:
Case management is a collaborative process of assessment, planning, facilitation, and advocacy for options and services to meet an individuals
able resources to promote quality cost-effective outcomes.
5
To fulfill this role and adhere to the intent if not the content of this definition, the case
manager is charged with coordination of transi­tional services as the patient moves to the next level of care and the next provider of services. This function is not limited to traditional dis­charges that occur at the end of inpatient admis­sions but also includes the coordination of care as the patient moves from the portal of entry to observational status and from observation to following level or site of care.
The multidisciplinary treatment team is charged with both the provision of care and patient empowerment, engagement, and education during any hospital stay or intervention. This includes every patient who receives observational moni­toring and care. Some outpatient environments employ case managers to provide effective care coordination. Other hospitals utilize members of the care delivery team to achieve this role. But, in every health care setting, care coordination must be an essential element of the stay and never be an afterthought or intended intervention that is not consistently delivered.
Care coordination as defined by the National Quality Forum (NQF) is a function that helps ensure that the patients needs and preferences for health services and information sharing across people, functions, and sites are met over time. It maximizes the value of services delivered to
high-quality patient experiences and improved health care outcomes.
6
Care coordination typically
encompasses the assessment of the patient’sneeds, the development and implementation of a plan of care, and an evaluation of the care plan.
Transitional care, a more targeted form of care coordination, is a set of actions designed to advance the coordination and the continuity of health care services as patients transfer between different locations or different levels of care within the same location.
7
In order to deliver efficient and
effective care coordination services, an appropriate handoverof the patient to subsequent care pro­viders and care givers is absolutely necessary. The initial step in this process begins when the patient enters the acute care facility seeking health care services and includes the following:
What is the patients primary concern
regarding their health status?
Did a member of the team perform a
comprehensive evaluation of past history and
current physical condition?
Nancy E. Skinner
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What is the name or names of HCP who provide or provided care to the patient in the past?
Has a member of the health care team attempted to reach out to that HCP to gain further information regarding the patients health status?
Has the patient made any decision regarding advance directives?
Which medications are currently being prescribed for the patient? Which medications have been prescribed in the past?
What medication regimen does the patient currently follow including over-the-counter medications?
Does a local pharmacy or pharmacy benefit manager fill current prescriptions?
What is the patients understanding of their current diagnosis or diagnoses?
Does the patient possess and maintain a personal health record?
After a determination is made regarding place­ment to observational status, who is primarily responsibility for assuring an appropriate hand­over of the patient to the HCP that will be man­aging that patients care during an observational stay? Additionally, the process of patient engage­ment, empowerment, and education must begin if it had not already been initiated in the emergency department or other portal to care. Education minimally includes information regarding the diagnosis and what that diagnosis means. It is vital that all education be provided based on the patients health literacy and cultural beliefs. Sub­sequent education is generally focused on moving the patient to self-management of their disease state and active participation in their plan of care.
As the patient prepares to transition out of observation to the next level of care, it is vital that each patient receives the following:
Verbal and written information regarding
their diagnosis and what that diagnosis means.
A copy of the prescribed treatment plan
including a medication list that has been
reconciled.
A list of the potential signs of disease
exacerbation and the steps to take if that
increase in symptoms occurs.
A referral to community-based care
management if those services are available in
the geographic region in which the patient resides.
An appointment for physician care in the community.
Although the following measures have not been implemented for outpatient environments as yet, the consistently changing and expanding regula­tions and reimbursement associated with a satis­factory patient experience are expected to touch outpatient services in the future.
8
To prepare for that probability, it is recommended that HCPs and acute care facilities that serve patients in outpatient settings begin to consider the Key Measures for the National Quality Strategy Priority.
9
One set of
those measures is detailed in Table 65.2.
Consider who within your current health
care delivery environment advances the patients ability to positively respond to those three key descriptors. If no one member of the team shoul­ders that responsibility, it is time to reengineer the transition of care in order to facilitate the timely movement of the patient through the health care continuum. It is my belief that the one member of the team who is this facilitator is the care coordin­ator or case manager. Their role must minimally include a role that reflects the established defin­ition of case management while achieving that delicate balance of fiscal responsibility and patient advocacy.
Table 65.2 Key Measures for National Quality Strategy Priority – Promoting Effective Communication and Coordination of Care
8
Measure Focus Key Measure Name/
Description
3-item care transition measure
During this hospital stay, staff took my preferences and those of my family or caregiver into account in deciding what my health care needs would be when I left
When I left the hospital, I had a good understanding of the things I was responsible for in managing my health
When I left the hospital, I clearly understood the purpose for taking each of my medications
Case Management: Care Coordination
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References
1. Medicare Benefit Policy Manual, CMS Pub. 100-02, Chapter 6, §20.6.
2. DHHS. National Strategy for Quality Improvement in Health Care. www.healthcare .gov/center/reports/national qualitystrategy032011.pdf March 2011.
3. Ibid.
4. OReilly, K. Health Reform Law Will Boost Care Quality. Amednews.com. www
.ama-assn.org/amednews /2010/12/20/prse1221.htm. June 2012.
5. Case Management Society of America Standards of Practice for Case Management, Revised
2010. www.cmsa.org/SOP. June 2012.
6. National Quality Forum (NQF) - Endorsed definition and framework for measuring care coordination. Available at www.qualityforum.org/ projects/care_coordination .aspx. June 2012.
7. Coleman EA, Berenson RA. Lost in transition: challenges and opportunities for improving the quality of transitional care. Ann Intern Med. 2004;141:533–536.
8. 2012 Annual Progress Report to Congress – National Strategy for Quality Improvement in Health Care. Corrected August 2012 and May 2014. www .ahrq.gov/workingforquality/ nqs/nqs2012annlrpt.pdf. June
2012. (Accessed April 2016)
9. Ibid.
Nancy E. Skinner
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