This week’s note is about the changes to the 2-Midnight Rule in the 2016 OPPS proposed rule. In the 2016 OPPS Proposed Rule, CMS announced that October 1, 2015 they will be transitioning the medical review of inpatient admissions from Medicare Administrative Contractors (MAC) to Quality Improvement Organizations (QIO). This policy will limit the future review of inpatient admissions by the Recovery Auditors and may be related to CMS’ withdrawal of the Request for Quotes for new Recovery Auditors announced July 10.
At many hospitals the terms Utilization Management (UM) and Utilization Review (UR) are used interchangeably. Are they the same thing? No, they're not, according to Stefani Daniels, RN, MSNA, ACM, CMAC, and Ronald L. Hirsch, MD, FACP, CHCQM.
CMS' Conditions of Participation for UR include specific requirements for the composition of the UR committee, specifying that it must be composed of at least two doctors of medicine or osteopathy.
The 2016 OPPS proposed rule is likely to continue CMS' trend of expanded packaging and feature refinements and expansion of comprehensive APCs based on comments CMS has made in prior rules.
Case managers rejoice. CMS recently sounded what is being called the death knell of the 2-midnight rule certification in a final rule published in the November 10, 2014, Federal Register.
Do observation patients belong in their own unit? The answer is debated at many organizations. Some say establishing a separate unit brings numerous advantages, from improved ED throughput to shorter lengths of stay. Others say some facilities may not need one.
