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Not many federal-issued mandates come with clear explanations. In fact, new rulings typically raise more questions than answers. The two-midnight rule is no exception. The policy, which centers on reimbursement for short-term treatments, came under fire from providers and inpatient facilities to the point that the Centers for Medicare & Medicaid Services has delayed its implementation, with Congress following suit.
In this month’s E-News Exclusive, an HIM manager attempts to make sense of the latest changes.
— Lee DeOrio, editor |
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After Midnight—or Two
By Cynthia C. Alder, RHIT, CDIP, CHDS, AHDI-F
On August 2, 2013, the Centers for Medicare & Medicaid Services (CMS) issued Final Rule CMS-1599-F, which affects CMS policy on Medicare review contractors who analyze inpatient hospital admissions for reimbursement. This rule states that when a patient enters a hospital for a surgical procedure, diagnostic studies, or any other purpose and the physician expects the patient will require hospital care for two or more midnights, the services provided will be considered appropriate for inpatient payment under Medicare Part A. According to these regulations, stays lasting fewer than two midnights should be treated and billed as outpatient services.
The CMS has delineated circumstances that are not considered appropriate for inpatient admission under the two-midnight rule, including admissions for telemetry monitoring, which the CMS states often is used in outpatient or observation settings. The CMS also clarifies that admission to a specific type of hospital unit is not, by itself, justification for inpatient admission status, and that circumstances must exist that support the expectation of a patient staying in the hospital over at least two midnights.
As with every rule, exceptions do exist, such as cases where treatments may require intensive care in an inpatient setting, such as new institution of ventilatory support.
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Security Breaches, Data Loss, Unplanned Outages Equal Big Costs
MeriTalk, a public-private partnership focused on improving the outcomes of health and government IT, has announced the results of its report “Rx: ITaaS + Trust.” HIT executives agree trusted IT solutions play a key role in enabling IT-as-a-service, an IT model that helps health care providers transform their extended IT infrastructure, improve service levels, deploy health care applications more quickly, and reduce costs. MeriTalk’s report quantifies the organizational cost associated with security breaches, data loss, and unplanned outages for health care providers—more than $1.6 billion a year—and provides insight into go-forward strategies.
Health information often is a target for malicious activity, and 61% of global health care organizations surveyed experienced a security-related incident in the form of a security breach, data loss, or unplanned downtime at least once in the past 12 months. Based on estimates from HIT executives in the EMC Global IT Trust Curve Survey, these incidents cost US hospitals an estimated $1.6 billion each year.
The MeriTalk study found that in the past 12 months, global health care organizations experienced the following:
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When a Hospital Stay Is Not a Stay
It’s often hard for patients to understand that spending the night at the hospital doesn’t make them an inpatient, The New York Times reports.
Some States Lag in Using EHRs
While nearly one-half of office-based physicians nationwide use EHRs, the adoption rate varies from 83% in North Dakota to 21% in New Jersey, according to the Pew Charitable Trusts. |
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Prepare for the Worst
HIT systems are vulnerable to Mother Nature’s whims and other unforeseen events, making it imperative for organizations to have a backup plan in place. Read more »
Too Much of a Good Thing?
Experts say a narrow approach to data analytics is more likely to produce the desired results. Read more »
Inside Job
Internal audits, whether they be coding or HIPAA related, can help providers stay ahead of new regulations. Read more »
Security vs. Usability
Patient portals must be mindful of data protection while satisfying user needs. Read more » |
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