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2014 IPPS Final Rule FAQ - November

Published on 

Tuesday, November 5, 2013

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2-Midnight Benchmark and Medicare Inpatient-Only Procedures

Question:

In light of the new 2-Midnight Benchmark for Physicians, does this mean that inpatient-only procedures that require a 1-day length of stay would now need to be billed as an outpatient?

Answer:

No, per the excerpt from the 2014 IPPS Final Rule below, admissions for a procedure on the Medicare inpatient-only list regardless of the length of stay should be an inpatient and billed as an inpatient stay.

“Comment: Commenters indicated that inpatient-only procedures that require a 1-day length of stay would be affected by this proposed policy and may not be adequately reimbursed under Medicare Part B. The commenters requested that CMS specify that all services on the inpatient-only list should automatically be deemed to meet inpatient service criteria, even if the beneficiary is in the hospital for less than 2 midnights. Conversely, another commenter suggested that excluding inpatient-only procedures, which may or may not require 2-midnight stays, contradicts a time-based policy.

Response: In the proposed rule, we stated that procedures on the OPPS inpatient-only list are always appropriately inpatient, regardless of the actual time expected at the hospital, so long as the procedure is medically necessary and performed pursuant to a physician order and formal admission. Procedures designated as inpatient-only are deemed statutorily appropriate for inpatient payment at § 419.22(n). As such, we believe that inpatient-only procedures are appropriate for exclusion from the 2-midnight benchmark. Under this final rule, inpatient-only procedures currently performed as inpatient 1-day procedures will continue to be provided as inpatient 1-day procedures, and therefore this rule will not result in any change in status or reimbursement.”

Source: Federal Register / Vol. 78, No. 160 / Monday, August 19, 2013 / Rules and Regulations 50947

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This material was compiled to share information.  MMP, Inc. is not offering legal advice. Every reasonable effort has been taken to ensure the information is accurate and useful.