New Regulations From CMS

Posted on Jan 7, 2014 in Clinical Documentation | 0 comments

The Center for Medicare and Medicaid Services (CMS) has come out with new regulations for determining inpatient and outpatient status for services provided in the hospital. In order to qualify as an inpatient, there must be a two midnight benchmark. Every decision to admit a patient to inpatient status should be based on the physician’s expectation that the hospital stay would span two midnights. Furthermore, that two midnight stay must be documented to be medically necessary. If a physician cannot reasonably expect the patient to spend two midnights in the hospital, then that patient should be admitted to observation status. If that patient then spends two midnights in the hospital, the status can be changed from observation to inpatient during that admission as long as medical necessity is documented in the medical record.

From a physician’s standpoint, documentation on admission needs to include an order to admit to inpatient status, the reason for inpatient services and the estimated time the patient will be hospitalized.

By Dean J. Nickles, M.D.
Medical Director, Utilization Management




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