CMS Issues Guidance on Short Term Inpatient Admissions

On August 2, 2013, the Centers for Medicare and Medicaid Services (“CMS”) published a final rule, effective October 1, 2013, regarding evaluation of inpatient hospital admissions.  This topic has received a high level of scrutiny from CMS due to short stays occurring in which patients would be admitted for less than one day.  The ultimate question being whether the patient should have received an outpatient level of care rather than the more expensive inpatient services under Medicare Part A.

Under the rule, CMS is now advising that inpatient hospital stays that include “2 midnights” will not be focused on by contractors in their review efforts.  This is important because it does provide a more defined benchmark that is consistent with the 24-hour period under prior guidance.  Nevertheless, there is still a need for a documented formal order of inpatient admission in the medical record.
This guidance from CMS does raise concerns with respect to stays that do not meet the two (2) midnight threshold.  For example, a patient may get admitted as an inpatient at 1:30 am and stay until 11:30 pm nearly 46 hours later and still not meet the threshold.  Finally, in the event an inpatient does not meet the two (2) midnight threshold, it is extremely important that your staff is trained on properly and thoroughly documenting such an event.  This guidance does provide answers; however hospitals should be mindful of short stays in general.  Recently a medical center was required to repay $1.09 million to the Federal government after an audit highlighted incorrect billing with respect to short stays.
Should you or your organization have any questions regarding the guidance discussed above or any other health care issues, please feel free to contact Robert A. Wade at 574-485-2002 or Alex T. Krouse at 574-485-2003.