Tag Archives: Two Midnight Rule

OIG Report Cites Continuing Vulnerabilities Under Medicare’s 2-Midnight Policy

The Office of Inspector General (OIG) of the Department of Health and Human Services (HHS) has issued a report, “Vulnerabilities Remain Under Medicare’s 2-Midnight Hospital Policy,” which assessed changes in hospital inpatient and outpatient stays since implementation of the “2-midnight” policy. This policy generally provides that an inpatient stay generally requires at least two midnights … Continue Reading

CMS Ends Temporary Suspension of Hospital “Two-Midnight” Short Stay Reviews

CMS has announced that it is allowing Beneficiary and Family Centered Care (BFCC) Quality Improvement Organizations (QIOs) to resume initial patient status reviews to determine the appropriateness of Part A payment for short stay inpatient hospital claims, effective September 12, 2016.  Such reviews had been “paused” since May 4, 2016 to promote consistent application of … Continue Reading

CMS Finalizes FY 2017 Update to Medicare IPPS, LTCH PPS Rates and Policies

The Centers for Medicare & Medicaid Services (CMS) has released its final rule to update Medicare acute hospital inpatient prospective payment system (IPPS) and long-term care hospital (LTCH) prospective payment system (PPS) payments and policies for fiscal year (FY) 2017.  With regard to the IPPS, CMS projects that the cumulative rate and policy changes in … Continue Reading

CMS Update on Temporary “Two Midnight” QIO Review Pause

CMS has temporarily “paused” Beneficiary and Family Centered Care (BFCC) Quality Improvement Organizations’ (QIOs) performance of initial patient status reviews under CMS’s “two-midnight policy” for short hospital stays. The pause, which took effect May 4, 2016, was a result of inconsistencies in the BFCC-QIOs’ application of the two-midnight policy and was intended to give CMS … Continue Reading

CMS Invites Comments on 2014 Medicare IPPS Rate Cut Due to 2-Midnight Policy Changes

CMS has published a notice with comment period describing its rationale for reducing Medicare inpatient prospective payment systems (IPPS) rates by 0.2% in FY 2014 to offset a projected $220 million increase in IPPS spending as a result of adoption of CMS’s “2-midnight” admission policy. The December 1, 2015 notice was issued in response to … Continue Reading

CY 2016 Medicare OPPS Spending to Drop by 0.4% under Final OPPS Rule; ASC Payments Get Small Boost

On November 13, 2015, the Centers for Medicare & Medicaid Services (CMS) is publishing its final rule updating the Medicare Hospital Outpatient Prospective Payment System (OPPS) and the Ambulatory Surgical Center (ASC) Payment System rates and policies for calendar year (CY) 2016. CMS estimates that total federal expenditures under the OPPS will drop by $133 … Continue Reading

CMS Updates Inpatient Hospital “Two Midnight” Review Education/Enforcement Strategy

CMS recently provided an update on its education and enforcement strategies related to its “Two Midnight” policy, which addresses when surgical procedures, diagnostic tests and other treatments are generally considered appropriate for inpatient hospital admission under Medicare Part A. The Medicare Access and CHIP Reauthorization Act of 2015 generally bars recovery audit contractors (RACs) from … Continue Reading

President Obama Signs MACRA: Permanently Reforms Medicare Physician Reimbursement Framework, Includes Other Health Policy Provisions

Today President Obama signed into law H.R. 2, the "Medicare Access and CHIP Reauthorization Act of 2015" (MACRA), which reforms Medicare payment policy for physician services and adopts a series of policy changes affecting a wide range of providers and suppliers. Most notably, MACRA permanently repeals the statutory Sustainable Growth Rate (SGR) formula, achieving a goal that has eluded Congress for years. Now, after a period of stable payment updates, MACRA will link physician payment updates to quality, value measurements, and participation in alternative payment models.… Continue Reading

OIG Responds to Hospital Compliance Review Objections

The OIG has defended its hospital compliance review policies in response to objections raised by the American Hospital Association (AHA). Specifically, a January 15, 2015 OIG letter addresses four main areas of AHA concern about the OIG’s application of Medicare rules and policies: (1) the need for a physician order, (2) the treatment of canceled surgeries, … Continue Reading

Congressional Health Policy Hearings

A number of Congressional panels have focused on following health policy issues recently, including the following: The House Ways and Means Health Subcommittee examined various Medicare hospital issues, including the CMS two-midnights policy, short inpatient stays, outpatient observation stays, Recovery Audit Contractor audits, and the appeals backlog. The House Energy and Commerce Committee held a hearing … Continue Reading

President Signs Medicare Physician Fee Schedule/SGR Patch with Numerous Health Policy Provisions

On April 1, 2014, President Obama signed into law H.R. 4302, the "Protecting Access to Medicare Act of 2014" ("the Act"). The Act includes a one-year Medicare physician fee schedule fix that averts a nearly 24 percent payment cut set for April 1, 2014, but which falls far short of earlier hopes for full repeal of the current sustainable growth rate (SGR) formula. The Act also includes numerous other Medicare payment and policy changes, including skilled nursing facility value-based purchasing provisions, reforms to the physician fee schedule relative valuation process, a new framework for clinical laboratory payments, a variety of changes impacting imaging services, changes in the exceptions for long term care hospitals, and extension of certain expiring provisions. In other areas, the bill includes a one-year delay in the transition to ICD-10, changes to the timetable for Medicaid disproportionate share hospital cuts, and "front-loading" of the 2024 Medicare sequestration reduction.… Continue Reading

Two-Midnight Inpatient Admissions Policy Guidance

CMS continues to provide guidance to providers and the MACs on its “2 Midnight Rule” Medicare inpatient hospital admission and medical review criteria. Additional updates were posted on March 12, 2014 to clarify review guidelines, questions and answers, and the mechanism to request redeterminations.… Continue Reading

CMS Continues to Modify Implementation of 2-Midnight Inpatient Admissions Policy

On February 24, 2014, CMS posted additional guidance on its controversial “2 Midnight Rule” Medicare inpatient hospital admission and medical review criteria. Among other things, CMS is requesting Medicare Administrative Contractors (MACs) to re-review claims denials made during the “probe and educate” phase of implementation to make sure that MACs are applying CMS clarifications issued in … Continue Reading

CMS Again Extends “Probe & Educate” Phase for 2-Midnight Inpatient Admissions Criteria Implementation; Clarifies Physician Certification Requirements

CMS has announced that it is extending provider education activities related to its new Medicare inpatient hospital admission and medical review criteria (commonly known as the 2-Midnight Rule). Specifically, CMS is extending what it refers to as the “Probe & Educate” review process for an additional six months, through September 30, 2014. Under this extension, … Continue Reading

CMS Call: 2-Midnight Benchmark for Inpatient Hospital Admissions (Jan. 14)

CMS is hosting a provider call on January 14, 2014 to discuss the Medicare inpatient hospital admission and medical review criteria (also known as the 2-Midnight Rule) included in the FY 2014 Medicare inpatient prospective payment system/long-term care hospital final rule. During the call, CMS will present case scenarios on the application of the rule … Continue Reading

CMS Guidance on Medicare Inpatient Hospital Admissions Two-Midnight Policy

CMS continues to release subregulatory guidance on the inpatient hospital admission/medical review criteria that were adopted in the final FY 2014 Medicare inpatient prospective payment system/long-term care hospital final rule. In short, under this new policy, if the ordering practitioner expects a beneficiary’s surgical procedure, diagnostic test, or other treatment to require a stay in the … Continue Reading

CMS Call on Inpatient Hospital Admissions 2-Midnight Policy (Nov. 12)

A November 12, 2013 CMS call will focus on the physician order, physician certification, inpatient hospital admission, and medical review criteria that were adopted in the final FY 2014 Inpatient Prospective Payment System/Long-Term Care Hospital final rule. In short, under this new policy, if the ordering practitioner expects a beneficiary’s surgical procedure, diagnostic test or other treatment … Continue Reading

CMS Limits Compliance Reviews under New “2 Midnight” Inpatient Admissions Policy

As discussed in previous reports, the final FY 2014 IPPS rule established new criteria for determining the appropriateness of inpatient admissions. In brief, under this policy, CMS generally will presume that surgical procedures, diagnostic tests, and other treatments are appropriate for Medicare Part A inpatient hospital payment when the physician admits a patient based on … Continue Reading

CMS Issues Guidance on Admission Order and Certification Requirements for Inpatient Admissions

As previously reported, the final FY 2014 Medicare inpatient prospective payment system (IPPS) rule established new criteria for determining the appropriateness of inpatient admissions. In brief, under this policy, CMS generally will presume that surgical procedures, diagnostic tests, and other treatments are appropriate for Medicare Part A inpatient hospital payment when the physician admits a … Continue Reading
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