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MedPAC Discusses Audit Reform, 3-Day SNF Rule

The Medicare Payment Advisory Commission (MedPAC) held its public meeting Sept. 11-12, during which the commissioners discussed alternatives to the Centers for Medicare & Medicaid Services’ (CMS’) two-midnight inpatient admission policy. Currently, the two-midnight policy creates a presumption that inpatient admissions that last fewer than two midnights are inappropriate for Medicare inpatient reimbursement. Concerns about the policy have caused CMS and Congress to delay enforcement of the policy until March 31, 2015.

During the meeting, the commissioners agreed that there is a need for a more targeted auditing system, largely due to the high error rates that are discovered when hospitals appeal their claim denials for short-stay admissions. Additionally, the commissioners discussed the impact of the two-midnight policy on the three-day rule for skilled nursing facility (SNF) admissions. Currently Medicare policy states that a beneficiary’s stay in a SNF will be covered if that beneficiary has been admitted to a hospital for three days prior to the SNF admission.

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


About the Author

Zina Gontscharow is a former senior policy analyst for America's Essential Hospitals.

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