Q&A: Billing for Part A reimbursement for an inpatient admission of less than two midnights

Q: Can we bill for Part A payment for an inpatient stay of less than two midnights if the physician expected the patient to meet the 2-midnight benchmark at the time of admission?

A: If the physician reasonably expects two midnights of hospital care but, due to unforeseen circumstances, the patient actually spends fewer than two midnights in the hospital, the case may nevertheless be appropriate for payment under Part A as an inpatient admission. CMS has provided the following examples of unforeseen circumstances:

• Unforeseen death
• Unforeseen transfer
• Departure against medical advice
• Election of hospice in lieu of continued hospital treatment
• Unexpected improvement of the patient resulting in discharge
• prior to the second midnight

The reasonable expectation of a 2-midnight stay and the unexpected nature of the patient’s shorter length of stay should be supported by the medical record. In the case of unexpected improvement, hospitals should exercise caution to ensure that the 2-midnight expectation was reasonable at the time the admitting physician wrote the inpatient order. If the 2-midnight expectation was not reasonable, review contractors may deny the case because it does not meet the 2-midnight benchmark.

For more information, see the Patient Status Training Toolkit for Medicare Utilization Review, Second Edition.