Teaching Hospitals Want CMS to Delay Implementing IPPS Inpatient Review Policy

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By Nathaniel Weixel  


A group representing teaching hospitals urged the Centers for Medicare & Medicaid Services in an Aug. 22 letter to delay implementing a provision in the fiscal year 2014 inpatient prospective payment system (IPPS) final rule related to the revised inpatient admission criteria.

The Association of American Medical Colleges (AAMC) told the agency there should be no enforcement of the provision before CMS issues guidance on “the many outstanding issues that need clarification, and providers have sufficient time to educate physicians and others about the new requirements and to make changes to electronic health systems that are needed to support the rules.”

AAMC said teaching hospitals need assurances that come Oct. 1 when the final rule takes effect, CMS will not deny coverage of inpatient admission by residents who are under the supervision of an attending physician.

The final IPPS rule was released Aug. 2 (21 HCPR 1339, 8/12/13). The provision AAMC is concerned about modifies and clarifies CMS's policy on how Medicare contractors review inpatient hospital admissions for payment purposes.

The policy instructs Medicare medical review contractors to presume an inpatient hospital admission is reasonable and medically necessary if a beneficiary requires more than one Medicare utilization day, which the agency defines as an encounter spanning “two midnights.” Under the final rule--in addition to services designated as inpatient-only--surgical procedures, diagnostic tests, and other treatments are generally appropriate for inpatient hospital admission and payment under Medicare Part A when the physician expects the beneficiary to require a stay that crosses at least two midnights and admits the beneficiary to the hospital based upon that expectation.

According to AAMC, the language in the final rule requires that the order to admit a patient be written by a practitioner “who has admitting privileges at the hospital,” something that few residents have as they are not considered members of the hospital's medical staff.

Six-Month Enforcement Delay After Guidance

AAMC said it brought the issue to CMS's attention during an Open Door Forum call Aug. 15. The agency acknowledged it did not intend to prohibit residents from admitting patients, and said it would be issuing a Q&A. However, AAMC said until the issue can be resolved “to the satisfaction of the teaching hospital community,” CMS should make clear to all contractors that no inpatient admission should be denied because it was ordered by a resident while under the supervision of an attending physician.

AAMC said CMS should delay enforcing the new requirements for at least six months following the release of the guidance so hospitals will have sufficient time to understand the rules, educate physicians and others, and ensure that they have put in place the mechanisms that are needed to comply with the new requirements.

“As short inpatient stays have been a focus of audits by [Recovery Audit Contractors], hospitals feel especially at risk for failure to properly implement CMS requirements,” AAMC said.

The letter is available at http://op.bna.com/hl.nsf/r?Open=nwel-9auqls.