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CMS Resumes Two-Midnight Reviews

Quality improvement organizations (QIOs) tasked with determining the appropriateness of short inpatient hospital stays have resumed their reviews of Medicare claims under the two-midnight policy.

In May, the Centers for Medicare & Medicaid Services (CMS) instructed QIOs to pause initial patient status reviews so the agency could conduct further education to ensure QIOs were consistently reviewing and applying the two-midnight policy for short inpatient stays. Last fall, CMS directed QIOs to take over initial patient status reviews. Recovery audit contractors previously held this responsibility.

In an announcement that QIOs would resume claim reviews Sept. 12, CMS noted that during the pause in reviews, QIOs completed retraining, re-reviewed denied claims, and conducted provider education on the two-midnight policy. The agency also indicated that it will continue to monitor QIO patient status reviews by examining a sample of completed claim reviews. QIOs will continue to offer provider education on the application of the two-midnight policy.

Providers wishing to contact CMS with questions related to the two-midnight policy should email

Contact Director of Policy Erin O’Malley 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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