With the current delay set to expire Sept. 30, CMS has extended the partial enforcement delay of the "two-midnight" rule through the end of the year.
Under the extension, Recovery Audit Contractors are prohibited from conducting post-payment patient status reviews for claims with dates of admission from Oct. 1 through Dec. 31, 2015.
American Hospital Association Executive Vice President Rick Pollack was pleased with CMS' decision to delay enforcement; however, he noted there is still work to be done. "We will continue to work with [CMS] as it finalizes its two-midnight policy changes and implements reforms to the flawed RAC program," he said.
In addition, CMS announced that beginning Oct. 1, Quality Improvement Organizations — groups of health quality experts, clinicians and consumers who work under direction of CMS — will assume responsibility for conducting initial patient status reviews to determine the appropriateness of Part A payment for short-stay inpatient hospital claims. These reviews were previously conducted by Medicare Administrative Contractors.
From Oct. 1 through Dec. 31, short-stay inpatient hospital reviews conducted by the Quality improvement Organizations will be based on Medicare's current payment policies. Beginning Jan. 1, 2016, Quality Improvement Organizations and Recovery Audit Contractors will conduct patient status reviews in accordance with the two-midnight policy changes finalized in the Outpatient Prospective Payment System rule and effective in calendar year 2016.
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