Many comments from hospital, physicians, and private citizens shared the opinion that every day spent under observation should count toward the three-day minimum stay required for post-acute care coverage under Medicare.
In its comments Premier, a healthcare alliance of more than 2,600 hospitals, stated that "beneficiaries in this outpatient status face the possibility that their aggregate copayments for all outpatient services received will exceed the inpatient hospital deductible."
It noted that observation is often "used for complex cases when it is not clear what level of service the patient needs." Premier asked CMS to consider providing physician education on medical necessity and the changing trends in the standards of care.
The American Academy of Otolaryngology recommended that CMS "automatically define anyone who has received care in the facility setting for more than 48 hours as an inpatient." It asked CMS to "increase the transparency of patient status for both patients and physicians" and implement an appropriate and consistent payment policy for both outpatient and short inpatient hospital stays.