CMS' 2014 IPPS final rule redefined inpatient admissions when it implemented the 2-midnight rule, which requires a validated physician order, documentation of medical necessity, and the expectation of a stay crossing two or more midnights.
This week’s note is about CMS’ offer to certain hospitals regarding withdrawing appeals for partial payments. Click the link above for more information and an in-depth analysis.
Modifier -25 (significant, separately identifiable E/M service by the same physician on the day of a procedure) is used to distinguish visits from procedures on the same day.
It is not used to distinguish observation from a visit service on the same day.
Documentation and billing for observation stays has come under increased scrutiny from the OIG, though many hospitals have struggled with changing regulations and frequently updated guidance.
