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CMS Pauses Two-Midnight Policy Reviews

The Centers for Medicare & Medicaid Services (CMS) has temporarily paused patient status reviews based on its two-midnight policy and will continue the delay until further notice.

The two-midnight policy established a time-based presumption of medical necessity for physician-ordered hospital inpatient Medicare admissions that span at least two midnights.

Quality Improvement Organizations (QIOs), which now conduct the initial status reviews instead of Medicare Administrative Contractors or Recovery Auditors, will work with CMS during the delay to ensure the two-midnight policy is applied consistently for all hospitals.

CMS also recently proposed reversing a 0.2 percent cut to hospital inpatient payments associated with the two-midnight policy. The payment reduction started in fiscal year 2014, despite a delay in policy enforcement.

Contact Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

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

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