Every now and then, the HCPro Boot Camp instructors are asked similar questions on a specific billing issue from students and clients across the country. The old saying “there must be something in the water” often holds true, and it does in this case, especially regarding recent OIG audits.
As CMS and third-party payers have looked for ways to treat patients in the outpatient setting and reduce inpatient volumes, CMS has used the 2-midnight rule, in addition to other methods, to treat patients as outpatients or in observation whenever possible.
In late June, CMS released a major proposed rule that hospitals will need to pay attention to—and no, I don’t mean to say that CMS released the CY 2018 OPPS proposed rule early, though we’ve thought that might happen since it’s been at the Office of Management and Budget (OMB) for several months.
