Case Management

Ask the expert: Is the three-day qualifying stay going away?

Case Management Insider, November 24, 2015

Under current Medicare rules, patients can only get coverage for a stay in a skilled nursing facility (SNF) if they’ve spent three consecutive inpatient days in a hospital. If they are receiving observation services, the stay does not quality for coverage. For example, if a patient spends one day in observation and two days as inpatient, even though they’ve spent three days in the hospital the stay does not meet the three-day inpatient day stay requirement. One of our readers recently approached us after hearing rumors that this requirement may soon be a thing of the past. So we asked expert Ronald Hirsch, MD, FACP, CHCQM, vice president of the Regulations and Education Group at Accretive Health in Chicago if the whispers are true or just wishful thinking.

Q: We are hearing that the qualifying three-day stay for coverage for a SNF stay may be going away effective January 1, 2016. Have you seen anything in writing?

This is totally false it would take action by Congress to abolish it completely. However, CMS did propose that the three-day requirement will be waived starting in year two of the Comprehensive Care for Joint Replacement program (which is still under review) and some pioneer accountable care organizations have been given permission to waive the requirement.

Got something you want to ask our experts? If you’ve got questions about the 2-midnight rule or any other case management topic, please e-mail them to Kelly Bilodeau at and we will have one of our experts answer it and will publish the response in an upcoming issue of Case Management Monthly.

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