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CMS Extends Partial Enforcement Delay of Two-Midnight Policy

The Centers for Medicare & Medicaid Services (CMS) has extended through Dec. 31 the partial enforcement delay of Medicare’s two-midnight policy.

This means recovery audit contractors (RACs) will not conduct postpayment reviews of patient status for claims with an inpatient admission between Oct. 1 and Dec. 31, 2015. For that period, quality improvement organizations (QIOs) will apply current two-midnight policy to initial patient status reviews to determine whether Medicare appropriately paid for short inpatient stays.

Before Oct. 1, Medicare administrative contractors (MACs) will conduct initial reviews. Starting Jan. 1, 2016, QIOs and RACs would conduct patient status reviews using revised guidelines CMS has proposed in its calendar year 2016 Outpatient Prospective Payment System rule.

Contact Beth Feldpush, DrPH, senior vice president of policy and advocacy, at bfeldpush@essentialhospitals.org or 202.585.0111 with questions.

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About the Author

Matt Buechner is the policy and advocacy associate for America's Essential Hospitals.

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