Health Information Management

News: Developments under ’two-midnight’ rule

CDI Strategies, December 19, 2013

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The American Hospital Association threw its support behind proposed legislation that would delay enforcement of the ‘two-midnight’ rule. Originally included in the 2014 IPPS Final Rule, the regulation changes the definition of medical necessity for inpatient admission to one in which the physician expects the patient to require inpatient services that could span more than two midnights.

(Read a related article and view a sample inpatient order in the October edition of CDI Journal. Details of the new language can be found at )

Due to subsequent confusion regarding the rule, CMS delayed enforcement from October 1, 2013 to March 31, 2014. A proposal before the U.S. House of Representatives seeks to extend that delay until October 1, 2014.

In a letter addressed to House Representative Jim Gerlach (R-PA) December 12, the AHA said it was “pleased to support” the legislation.

“[T]here is not enough time for hospitals and physicians to adjust,” the letter states. “Providers need additional time to reevaluate and potentially change many internal policies, update existing electronic medical records systems, and alter work flow processes to ensure compliance with the two-midnight policy.”

The letter further laments that CMS has done little to date to help providers understand the new rule, stating that the agency has “issued only minimal guidance—much of which lacks clarity and only raises new questions for both hospitals and physicians.”

For its part, CMS will hold an Open Door Forum on the topic today, December 19, at 1 p.m., Eastern, and it plans to address the matter during a National Provider Call on January 14.

According to the proposed legislation, Medicare contractors will not be permitted to deny claims based on the length of an inpatient stay during the delay. The legislation also includes recommendations for new payment methods for short inpatient stays to be implemented in fiscal year 2015.

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