CMS extends two-midnight partial enforcement delay

As urged by the AHA, the Centers for Medicare & Medicaid Services today extended through Dec. 31 the partial enforcement delay of the two-midnight policy. The current delay was set to expire Sept. 30. 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. In addition, CMS provided further details related to previously announced changes in the agency’s education and enforcement strategies for patient status claims. Specifically, beginning Oct. 1, Quality Improvement Organizations will assume responsibility for conducting initial patient status reviews to determine the appropriateness of Part A payment for short-stay inpatient hospital claims. From Oct. 1 through Dec. 31, 2015, patient status reviews conducted by the QIOs will be based on Medicare’s current two-midnight policy. Beginning Jan. 1, 2016, patient status reviews will be conducted in accordance with any policy changes finalized in the Outpatient Prospective Payment System rule and effective in calendar year 2016. In addition, CMS announced that the third round of Probe and Educate reviews is expected to be completed by Sept. 30, 2015. For more on the announcement, visit www.cms.gov. Rick Pollack, AHA executive vice president, said the association was pleased with today’s announcement and appreciative of the detail provided. “We will continue to work with the agency as it finalizes its two-midnight policy changes and implements reforms to the flawed RAC program,” he said.