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CMS Extends Two-Midnight Policy Enforcement Delay

The Centers for Medicare & Medicaid Services (CMS) updated its guidance on the two-midnight policy, extending its enforcement delay through March 31, 2015. CMS previously delayed enforcement of the two-midnight policy until Sept. 30, 2014, and is continuing the delay to comply with requirements in the Protecting Access to Medicare Act of 2014.

During the delay, Medicare administrative contractors (MACs) and recovery audit contractors will not conduct postpayment patient status reviews on inpatient admissions with dates of admission between Oct. 1, 2013, and March 31, 2015. MACs will continue to conduct prepayment probe reviews of short stays for a sample of 10 claims per hospital (25 claims for large hospitals) to assess hospitals’ compliance with the Medicare inpatient admission guidelines.

Please contact Xiaoyi Huang, director of policy, at or 202.585.0127 with questions.


About the Author

Shahid Zaman is a senior policy analyst at America's Essential Hospitals.

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