Health Information Management

Tip: CMS looks to add new modifier to identify services performed prior to C-APCs

APCs Insider, September 18, 2015

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Providers anticipated an update to the 2-midnight rule in the 2016 IPPS final rule released April 17, but CMS noted that it was still collecting information and would provide more information in the OPPS proposed rule. CMS followed through with an update to the 2-midnight rule in the 2016 OPPS proposed rule.
CMS proposes that for stays a physician expects to last less than two midnights, it will accept an inpatient admission on a case-by-case basis, depending on the judgment of the physician and the documentation justifying the stay. CMS expects short stays for minor surgical procedures or hospital care to be rare and will monitor these types of admissions to prioritize them for medical review.
Quality Improvement Organizations (QIO) would take over responsibility for educating physicians and enforcing the 2-midnight rule from Recovery Auditors, according to the proposed rule. This appears to be a positive change, as the QIOs are likely better equipped than Recovery Auditors to conduct these reviews, but providers will know more once CMS releases information about the medical review strategy.
This tip is adapted from “CMS proposes massive APC reconfiguration, updates 2-midnight rule" in the September issue of Briefings on APCs.

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