Q&A: More on the BFCC-QIO Audits

Q: What’s the latest with regard to Beneficiary and Family Centered Care Quality Improvement Organizations (BFCC-QIO) short-stay reviews?

A: KEPRO, one of the two BFCC-QIOs reviewing short stays for CMS, recently released its own FAQ about the reviews and what to expect.

A few of the highlights from KEPRO that organizations should be aware of are as follows:

• The admit order written on the day of discharge after two midnights is allowed.
• KEPRO will use IQ as a screening for medical necessity for hospital care not for proper level of care.
• KEPRO admitted certification is no longer needed. Kepro stated: “Physicians do not need to include a separate attestation of the expected length of stay; rather, this information may be inferred from the physician’s standard medical documentation, such as his or her plan of care, treatment orders and physician’s notes.”
• The doctor stating "I expect two midnights" is unnecessary and not helpful.
• Citing “no safe discharge plan” is not an indication for inpatient admission.
• KEPRO declined to not define “extensive delay.” They only repeated what CMS has already stated: “Examples of extensive delays could include, but are not limited to, inability of hospital to provide services such as CT scans, MRIs, cardiac catheterizations over a weekend.”
• Occurrence code 72 will not exclude a chart from audit. KEPRO stated: “It’s KEPRO’s understanding that Occurrence Code 72 was developed in order for providers to identify where there were observation days. It’s a voluntary code that hospitals can use when submitting a claim. Claims utilizing this code will be subject to review.”
• KEPRO would not address the new exception for physician judgment on one midnight stays other than saying they will review the record in its entirety "for the reasonable expectation the patient required medically necessary inpatient hospital services.

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