“I Know It When I See It”

In 1964, there was a Supreme Court decision—Jacobellis v. Ohio—on the First Amendment and how it applied to the showing of a movie. The Supreme Court ruled that the First Amendment does not permit censorship. The most famous opinion in that decision was by Justice Potter Stewart who wrote “I shall not today attempt further to define the kinds of material I understand to be embraced within that shorthand description; and perhaps I could never succeed in intelligibly doing so. But I know it when I see it, and the motion picture involved in this case is not that.”. . .

The phrase “I know it when I see it” has become a colloquial expression whereby a speaker attempts to categorize an observable fact or event, although the category is subjective or lacks clearly defined parameters.

This expression can be applied to hospitals in their efforts to distinguish Implantable Devices charged to patients from regular billable Medical Supplies. CMS has never provided any specific guidance, only that hospitals should report UB revenues codes 0275 – pacemaker, 0276 – intraocular lens, 0278 – other implants and 0624 – Food and Drug Administration (FDA) investigational devices on line 72.

Some general guidance is given that instructs hospitals to have an established charge structure which is applied uniformly to each patient as services are furnished which is reasonably and consistently related to the cost of providing the services.

Tip #32:

The identification of billable Medical Supplies versus Implants is at the hospital’s discretion, but ensure you have a uniform charging structure that could withstand CMS scrutiny (CMS Pub 15-1, Section 2203).

Further guidance can be found on the Centers for Medicare and Medicaid Services (CMS) website:

Provider Reimbursement Manual 15-1

Questions? Please contact Marie White at 612.253.6546 or mewhite@eidebailly.com.

 

Miscellaneous Expenses: Almost Like the Honor System at a Country Store

Rural Store Market Building in Country Small Town AmericaHave you ever shopped at a country store that operates on the honor system to pick-up miscellaneous produce? The Merriam-Webster Dictionary defines miscellaneous as: “consisting of diverse things or members.” In accounting terminology, the common usage is miscellaneous expense and is defined as: “An income statement account for expense items that are too insignificant to have their own separate general ledger accounts.”

CMS provides some guidance in identifying the types of miscellaneous expenses and other income that is required to be offset. Just like at a store on the honor system, it is your responsibility for reviewing these amounts and ensuring they are documented accordingly—only CMS will retroactively hold you accountable if you misstate amounts on your cost report.

A helpful tip to remember is if the income is not related to care of hospital patients, then odds are, it should be offset!

Tip #20:

Miscellaneous revenue or income should be offset via Worksheet A-8 (Pub. 15-2, Section 4016).

Further guidance can be found on the Centers for Medicare and Medicaid Services (CMS) website:

Provider Reimbursement Manual 15-2, Chapter 40

Questions? Please contact Marie White at 612.253.6546 or mewhite@eidebailly.com.