Compliance

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 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.

SHM's course, Evaluation & Management Principals for Hospitalists, is the only one designed specifically for hospitalists. It will empower participants to document and code accurately and completely, so they are appropriately reimbursed for the work they do.  

More Information

Other Member Resources on Hospital Medicine Coding and Clinical Documentation:

• 2023 Hospital Medicine Evaluation and Management Guidelines
• 2024 Policy Update on Medicare Policy on Split (or Shared) Billing for E/M Services
• MDM Grid for Hospitalists
• Webinar: Navigating Clinical Documentation and Case Mix Index (CMI)
• Webinar: 2023 Changes to Hospitalist E/M Billing Codes
• And more!

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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.

Effective January 2023, all health care providers with a DEA registration that includes Schedule III authority can prescribe buprenorphine to treat patients with Opioid Use Disorder. An X-Waiver is no longer required to prescribe buprenorphine. This change follows the passage of the Mainstreaming Addiction Treatment (MAT) Act in December 2022.

In addition, per the Medication Access and Training Expansion (MATE) Act, starting June 27, 2023 all health care practitioners who apply newly for or seek to renew their DEA registration will be required to complete 8 hours of relevant accredited education related to the prevention, recognition, and care of people with substance use disorders. The 8 hours can be satisfied through a combination of activities and do not have to be included in one session.

For more information, including links to SHM activities that count towards the attestation of training completion, please visit DEA Licensure Requirement.

How did we get here?

In 2000, Congress passed the Drug Addiction Treatment Act (DATA 2000), which created the X-Waiver program to enable waivered clinicians to prescribe buprenorphine outside of methadone clinics and similar settings. Because the X-Waiver required additional steps and training, Medication-Assisted Treatment (MAT) with buprenorphine has been underutilized. Since 2018, SHM has advocated for the elimination of the X-Waiver so that hospitalists can more effectively treat patients with opioid use disorder and be able to prescribe this lifesaving medication at discharge.

In December 2022, the omnibus funding package signed by President Joe Biden effectively cancelled the X-Waiver requirements for physicians and NPs/PAs to prescribe buprenorphine.

Below are statements from the SAMHSA:

• SAMHSA: Removal of DATA Waiver (X-Waiver) Requirement

Webinar Recording: How to be a Hospitalist Opioid Use Disorder Champion: Improving the Quality of Care for Patients 

Recorded on January 28, 2025, this webinar discusses the current state of addiction medicine and the roles that hospitalists can take within their practice to overcome barriers and improve the quality of care for their patients with opioid use disorder.  Topics include how to screen patients, building protocols and pathways, QI projects, orders for discharge, and linkage to care.  Additionally, speakers discuss how to acquire data on the issue and how to start building capacity within the hospitalist team.

View Recording

Webinar Recording: How to be a Hospitalist Opioid Use Disorder Champion: OUD Consult Services

Recorded on Thursday, February 13, 2025, this webinar focuses on the creation of OUD consult services. In addition to the structure of these service lines, we explore the role that culture plays in OUD treatment.  Participants will understand how to assess readiness for consult services within their own institutions, develop support and find partners, define metrics, and activate the model.  We also discuss various funding opportunities for these programs.

View Recording

Articles about OUD Treatment

• Implementation of a comprehensive hospitalist-led initiative to improve care for patients with opioid use disorder (article in JHM)
• Hospital Buprenorphine Program for Opioid Use Disorder Is Associated With Increased Inpatient and Outpatient Addiction Treatment (article in JHM)
• The Hospitalist Role in Treating Opioid Use Disorder (article in The Hospitalist)