tci ED Coding & Reimbursement Alert - 2014 Issue 6

Facility Observation Audits: Prepare For Audit Intensity With the Two-Midnight Rule

Review the CMS requirements for observation care, because they are observing your code choices CMS implemented the controversial “Two-Midnight Rule” that directs Medicare contractors to assume hospital admissions are reasonable and necessary for patients who stay in a hospital through two midnights. Hospital stays that are shorter are presumed legitimate if coded as outpatient observation proper documentation of admission to observation orders and the required minimum time thresholds. Make Sure You Get Credit for Any Observation Time Prior To Admission The two-midnight rule requires that patients admitted to the hospital are expected to be hospitalized over two midnights...

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