Q&A: Preparing for potential elimination of inpatient-only list

Q: In the 2021 OPPS proposed rule, CMS suggested that there is no longer a need for the inpatient-only list. What could this mean for case managers going forward?

A: The possible elimination of the inpatient-only list is both good news and bad news for case managers, says Ronald Hirsch, MD, FACP, CHCQM, vice president with the Regulations and Education Group at R1 Physician Advisory Services in Chicago.

“The inpatient-only list is widely hated since it is so prescriptive and it is often hard to know the HCPCS code of a planned surgery to determine if it is on the list,” says Hirsch. “Getting rid of the list will remove that burden. But it adds the burden of having to decide on the right status based on a much more subjective method: looking at the estimated length of stay and risk.”

The 2-midnight rule will apply to surgeries that are removed from the list, as it does currently for hip and knee replacement procedures, according to Hirsch. Surgeries performed as a same-day procedure with no overnight stay would always be performed on an outpatient basis. However, if a patient is expected to need two midnights of care following the procedure, the surgery would qualify as an inpatient procedure.

For more information, see the September issue of Case Management Monthly.