Sept. 9—The Centers for Medicare & Medicaid Services (CMS) aimed to clarify details surrounding a change to hospital admissions under Medicare through new guidance.

The CMS issued so-called subregulatory guidance Sept. 5 that specified the steps hospitals need to take to admit a patient under Medicare’s inpatient admission rules that go into effect Oct. 1. 

“This ruling addresses a number of important issues left unresolved by the two-midnight provisions included in the 2014 final IPPS rule,” said Chad Mulvany, director, healthcare finance policy, strategy and development at HFMA. “It clears up a number of issues and provides clarity on key items like what needs to be included in an admission order, the timing of that order, and how verbal orders are to be handled.”

Taking a Closer Look

The 2014 Inpatient Prospective Payment System final rule published Aug. 2 established new requirements for CMS coverage of Part A inpatient hospital claims—in part, by formalizing requirements for physician orders. The rule also created new requirements that hospitals determine “medical necessity” before admitting Medicare patients under Part A. 

The admission rule changes came after hospital advocates raised growing alarm in recent years that complex and opaque rules delineating allowable admissions have exposed hospitals to a large and growing number of adverse findings from Medicare contract auditors. They complained that the changes scheduled to go into effect in October had not clarified the rules.

For instance, a June 24 letter from HFMA President and CEO Joseph J. Fifer to CMS administrator Marilyn Tavenner asked the agency to further detail the required admission procedures first outlined in a proposed rule earlier this summer.

The new subregulatory guidance specified the new paperwork required for hospital admissions, including physician certifications and medical record documentation.

Two-Midnight Rule Comes into Focus

To determine hospital inpatient services were “reasonable and necessary” and provided in accordance with the so-called two midnight benchmark, which begins Oct. 1, physicians would need to estimate how long the beneficiary needed hospitalization.

The guidance specified the timeframe for completion and submission of a physician certification, and what qualifying elements patient records must contain.

Physician orders to admit patients also must include either specific terminology or reference services typically rendered at inpatient settings, according to the guidance.

Publication Date: Monday, September 09, 2013