If your organization is like many others, you've probably still got some lingering questions about how to comply with the 2-midnight rule. During a recent HCPro webcast "Medical Necessity Documentation and Short Stays," Steven Greenspan, JD, LLM, vice president of regulatory affairs at Executive Health Resources in Newtown Square, Pennsylvania, and Kurt Hopfensperger, MD, JD, vice president of compliance and physician education for Executive Health Resources, tried to shed some light on areas of confusion.
A new notification requirement is coming next summer. Under the law, the Notice of Observation Treatment and Implication for Care Eligibility (NOTICE) Act, which was signed by President Barack Obama on August 6, any patient in observation who has been in the hospital for more than 24 hours must be clearly told?verbally and in writing?of his or her outpatient status. Hospital officials have to deliver this notification no more than 36 hours after the patient's outpatient treatments begin.
After years of wavering and waffling, ICD-10 was finally set to become a reality on the first of October. The extent to which this new set of codes for medical diagnoses and inpatient hospital procedures will affect you depends largely on how your role is structured, says Stefani Daniels, RN, MSNA, CMAC, ACM, founder and managing partner of Phoenix Medical Management, Inc., in Pompano Beach, Florida.
Compliance with the 2-midnight rule has been tricky for many organizations?and things aren't expected to get easier anytime soon. The 2016 OPPS proposed rule may bring some additional tweaks to the 2-midnight rule (see related story, "Proposed OPPS rule suggests tweaksto 2-midnight rule," in the September issue of CMM), and education and enforcement may change hands from Recovery Auditors to Quality Improvement Organizations.
Today's nurses have more demands on them than ever, with high patient loads and an increasing number of tasks to complete. Often, this increases the likelihood that certain aspects of care may be missed?whether it's needed education on insulin injections that weren't provided before discharge or a patient who develops a pressure ulcer because he or she wasn't turned often enough.
