News & Analysis as of

Inpatient Billing Medicare Part A Centers for Medicare & Medicaid Services (CMS)

King & Spalding

OIG Report Details Weaknesses in Enforcement of Two-Midnight Rule

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CMS estimates that between 2017 and 2021, Medicare Part A improperly paid $23.9 billion for inpatient hospital stays, with $7.8 billion attributable to short stays that did not qualify for Medicare Part A. On June 13, 2024,...more

Health Care Compliance Association (HCCA)

CMS offers correct billing tips for nonphysician outpatient services provided before or during inpatient stays

Compliance Today (March 2021) - The Centers for Medicare & Medicaid Services (CMS) has provided the following compliance notice: “In a recent report, the Office of Inspector General (OIG) determined that Medicare made...more

Health Care Compliance Association (HCCA)

Court Says Inpatients Changed to Observation Have Right to Appeal, Orders New Process

Report on Medicare Compliance 29, no. 12 (March 30, 2020) A federal court on March 24 ordered CMS to let Medicare patients “challenge decisions by hospitals” to change their status from inpatients to observation, dating...more

King & Spalding

How Payers Are Improperly Underpaying Inpatient Services As Observation Services

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Health plans and their delegated IPAs are using a number of different tactics to deny payment for inpatient services by improperly classifying inpatient claims as observation or other types of outpatient status. Payers are...more

Robinson+Cole Health Law Diagnosis

CMS Revises Hospital Inpatient Admission Order Documentation Requirements

On August 17, 2018, the Centers for Medicare & Medicaid Services (CMS) published its Hospital Inpatient Prospective Payment Systems final rule for Fiscal Year 2019 (Final Rule). The Final Rule contains a number of important...more

Baker Donelson

CMS Softens Physician Inpatient Order Documentation Requirement

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Effective for hospital inpatient admissions on or after October 1, 2018, CMS has removed the requirement that a signed physician order must be present in the medical record to establish inpatient coverage. While this guidance...more

Baker Donelson

OIG Finds Acute Care Hospitals Improperly Billed for Outpatient Services Provided to Inpatients of Other Hospitals

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Acute care hospitals that provide Medicare outpatient services to inpatients of other hospitals should be billing and collecting payment from the other inpatient hospitals and not from Medicare....more

Akerman LLP - Health Law Rx

Two-Midnight Rule Update

The Centers for Medicare and Medicaid Services (CMS) announced a further delay, through December 31, 2015, of the Recovery Auditors’ (RA) audits of the “Two-Midnight” Rule. Congress previously passed a law delaying...more

BakerHostetler

CMS Releases CY 2016 OPPS Proposed Rule With Updates to Two-Midnight Rule and Other IPPS Proposals

BakerHostetler on

On July 1, 2015, the Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2016 outpatient prospective payment system (OPPS)/ambulatory surgical center (ASC) payment system proposed rule that...more

McDermott Will & Emery

CMS Proposal Broadens Medicare Inpatient Reimbursement Eligibility Under the “2-Midnight Rule"

On July 1, 2015, the Centers for Medicare & Medicaid Services (CMS) released proposed updates to the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System for Calendar Year...more

King & Spalding

2-Midnight Inpatient Admission Policy

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Under CMS’s modified inpatient admission guidelines adopted in the IPPS Final Rule, Part A payment is “generally inappropriate” unless the patient is admitted based on the physician’s expectation that the patient will require...more

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