The chargemaster is both a direct and indirect target of compliance and thus various types of audits.  Hospitals should periodically take the time to examine their chargemasters from a compliance perspective.  This means examining and reviews various CDM policies and procedures (P&Ps) which must dovetail to coding P&Ps as well as billing P&Ps.  Issues such as transparent pricing, proper use of revenue codes, cost report interface, coding interface, billing interface, supply categorization, etc. must all be considered.  A systematic process for auditing the chargemaster relative to this host of compliance issues is discussed.

  • Why is the chargemaster a direct target for compliance?
  • Are formal, chargemaster policies and procedures important?
  • Should the chargemaster be routinely reviewed as a good compliance practice?
  • What is all the concern about archiving the chargemaster?
  • Are statutory and contractual requirement for the chargemaster significantly different?
  • Why has chargemaster pricing become such a hot compliance issue?
  • How can we know that our chargemaster is in compliance?
  • Are the revenue codes really important?

Session Objectives:

  1. To review the purpose, function and organization of the chargemaster.
  2. To appreciate that the chargemaster is both a direct and indirect concern for compliance.
  3. To appreciate the difference between statutory and contractual compliance issues.
  4. To discuss the attributes that are necessary to maintain chargemaster compliance including revenue codes, CPT/HCPCS codes and pricing.
  5. To appreciate the compliance areas that may be reviewed by external auditors and governmental entities including the RACs.
  6. To appreciate the indirect impact that the chargemaster has on other compliance concerns including coding, billing and payment.
  7. To understand the differences between separately charging and separately billing or separately reporting.
  8. To appreciate the proper use of revenue codes and the potential impact on the cost report.
  9. To discuss the development of CDM P&Ps which must properly correlate to coding P&Ps and billing P&Ps.
  10. To review various compliance issues related to the CDM and the policy decisions that must be made in order to maintain compliance.
  11. To appreciate different levels and forms of guidance from CMS, which sometimes conflict.

Session Agenda:

  1. Overview of the Chargemaster
    1. Role, Purpose, Function and Organization
    2. Chargemaster Interfaces
    3. Direct versus Indirect Compliance Concerns
  2. Types and Levels of Compliance Concerns
    1. Statutory Requirements
      1. Medicare
      2. Other Governmental Programs
    2. Contractual Obligations
      1. In the Contracts
      2. References to Companion Manuals
  3. Chargemaster Compliance
    1. Internal Code Sets
    2. Correlation of Line Items
    3. Proper Assignment of Revenue Codes
    4. Proper Pricing and Charge Structures
    5. Developing Proper Cost-to-Charge Ratios (CCRs)
  4. Indirect Areas of Chargemaster Compliance
    1. Cost Report
    2. Cost Accounting
    3. Correct Coding
    4. Proper Claim Generation
  5. Governmental Auditing Programs
    1. Levels and Types of Rules and Regulations
    2. Ambiguous and Conflicting Guidance
    3. DOJ and CMS
    4. RACs
  6. Sources for Further Information
Related Courses:

Suggested Attendees:

  • Healthcare Executives
  • Physicians
  • Chargemaster Personnel
  • Coding Personnel
  • Billing and Claims Transaction Personnel
  • Chargemaster Coordinators
  • Cost Report Preparers
  • Compliance Officers and Compliance Personnel
  • Auditing Personnel
  • Revenue Cycle Personnel
  • Clinical Service Providers
  • Financial Analysts

About The Presenter:

Duane C. Abbey, PhD, CFP, is a management consultant and president of Abbey & Abbey Consultants, Inc., a consulting firm specializing in health care and related areas. Duane earned his graduate degrees at the University of Notre Dame and Iowa State University and has more than 20 years of experience as a consultant. Dr. Abbey works extensively in all areas relating to compliance reviews,coding, billing and reimbursement with particular emphasis on the chargemaster and outpatient payment. His consulting activities include hospitals and physicians based clinics.

In addition to his consulting practice, Dr. Abbey also teaches workshops and makes presentations on a regular basis. He has taught at the University level and speaks nationally. He is a regular presenter for hospital associations, medical societies, Boards of Trustees and various other organizations and groups. In addition, professional societies such as HFMA use Dr. Abbey’s services to present seminars and workshops.

Dr. Abbey is a nationally recognized expert in payment systems. A special area of expertise includes APGs/APCs. He is recognized as the leading expert in the nation in APGs/APCs by the thousands who have attended his seminars, read his publications and/or contracted for his services. Attendees at these seminars over the years have included personnel from hospitals, clinics, integrated delivery systems and multiple consulting firms.

Dr. Abbey is also the author of numerous articles and books including: Compliance for Coding, Billing & Reimbursement, Outpatient Services: Designing, Organizing & Managing Outpatient Resources, ChargeMaster: Review Strategies for Improved Billing and Reimbursement, Ambulatory Patient Group Operations Manual, published by McGraw-Hill and Non-Physician Providers: Guide to Coding, Billing & Reimbursement, Chargemasters: Strategies to Ensure Accurate Reimbursement and Compliance, and Emergency Department Coding & Billing: A Guide to Reimbursement & Compliance published.

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