Effective Oct. 1, hospitals can generally count on Medicare payments for inpatients who are in a bed by midnight and remain there for more than 24 hours, according to the new 2014 inpatient prospective payment system rule finalized by CMS on Aug. 2. Shorter stays won’t get the benefit of the doubt unless patients are having procedures on the inpatient-only list. Sounds simple enough, and while it’s designed to provide clarity in an area of great confusion, hospitals have to worry about physician orders, counting hours, ensuring services provided were medical necessary and rebilling Part B within a year of the date of service if the admission is denied. Hear the DOs and DON’Ts of CMS’s new two-midnight rule from two experienced health lawyers who specialize in Medicare audit defense and appeals.
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CMS’s new two-midnight threshold for inpatient admissions is a double-edged sword. Auditors will presume inpatient stays that cross at least two midnights are medically necessary, but they will be on the lookout for hospitals that may game the system (e.g., perhaps delaying discharges to qualify for the MS-DRG payment). At the same time, auditors will double down on short stays, which had an improper payment rate of about 36% last year. While hospitals should be thankful for clarity on these issues, with government simplification comes tricky new questions. When does the clock start ticking? What hospital services or treatments can be counted toward the two-midnight threshold? What pitfalls should hospitals avoid in their compliance with this new standard?
Hear from two experts in Medicare audit defense and appeals who will help you rethink your audit defense strategies and compliance procedures in light of the new two-midnight rule. You and your compliance team will get answers to these and other key questions:
ABBY PENDLETON and JESSICA L. GUSTAFSON are founding partners with the health care law firm of The Health Law Partners, P.C. Pendleton and Gustafson co-lead the firm's Recovery Audit Contractor (RAC) and Medicare practice group, and specialize in a number of areas, including: RAC, Medicare, Medicaid and other payor audit defense and appeals, health care regulatory matters, compliance, HIPAA privacy & security compliance matters, overpayment refunds, reimbursement and contracting matters, and payor de-participation matters. Pendleton and Gustafson also regularly assist attorneys with their health care legal needs.
Moderator: Francie Fernald, contributing editor of AIS's Report on Medicare Compliance
Compliance officers, billing and coding managers, reimbursement directors, internal auditors, legal counsel, and financial and operations executives at
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