The American Hospital Association has sent a letter to CMS asking it to offer solutions to the two-midnight rule in its proposed fiscal year 2016 inpatient prospective payment system rule.
Under the two-midnight rule, CMS generally considers hospital stays of less than two midnights to be outpatient cases, while stays spanning two midnights are appropriate for payment under the IPPS rule.
"The two-midnight policy results in inadequate reimbursement to hospitals for beneficiaries who require an inpatient level of care, but who stay in the hospital less than two midnights," the AHA wrote.
In its letter, the AHA provided several potential short stay payment policy approaches that could supplement the existing two-midnight policy to more accurately reimburse hospitals.
The AHA hopes the analysis it provided will be used by CMS as it drafts the FY 2016 IPPS proposed rule.
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