Two-Midnight Rule: Initial Reviews to Resume

HealthLeaders Media News, September 14, 2016

Two-Midnight Rule: Initial Reviews to Resume

Having taken time out for retraining and internal audits, contractors may resume initial-phase reviews of Medicare reimbursement claims for short-stay inpatient hospital care, CMS says.

The Centers for Medicare & Medicaid Services has cleared resumption of initial-phase reviews for Medicare claims under the so-called two-midnight rule.

CMS suspended the initial-phase reviews, which are conducted by Beneficiary and Family Centered Care-Quality Improvement Organizations (BFCC-QIOs), on May 4.

In an announcement Monday lifting the suspension, CMS officials said the BFCC-QIO claims reviews were temporarily halted to retrain the contractors: "CMS took this action in an effort to promote consistent application of the medical review policies regarding patient status for short hospital stays and to allow time to improve standardization in the BFCC-QIOs' review process."


Suspension of Two-Midnight Rule Reviews Could Last Through July


Under the two-midnight rule, which has been in place since October 2013 and significantly revised in October 2015, most hospital stays spanning a period of less than two midnights are considered inappropriate for designation as inpatient status and are ineligible for Medicare A reimbursement.

The two-midnight rule changes made in October included making BFCC-QIO's responsible for the initial-phase review of Medicare claims under the short hospital stay regulation. Before October, Recovery Audit Contractors conducted the initial-phase reviews.

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