The Centers for Medicare & Medicaid Services’ (CMS) hospital compliance requirements are ever-changing and evolving. But sometimes, the CMS Hospital Conditions of Participation (CoP) requirements and Hospital Inpatient Prospective Payment System (IPPS) rule revisions change for the better.
Case in point: You can expect changes to the CMS Hospital CoP requirements and some documentation updates for 2019, according to hospital compliance expert Sue Dill Calloway in her webinar, “Documentation Update 2019: Ensuring Compliance.” Proper documentation is more important than ever before – and your reimbursement is now tied to the quality of your medical records.
Enjoy a Reprieve from These Types of Denials
A key change in the 2019 Hospital IPPS final rule was a revision to the requirement that you document the inpatient admission order in the medical record, according to Health Law Diagnosis. The final rule removed the requirement that an inpatient admission order “must be present in the medical record and be supported by the physician admission and progress notes, in order for the hospital to be paid for hospital inpatient services under Medicare Part A.”
This revision is effective as of Oct. 1, 2018. CMS will no longer require you to include a written inpatient admission order in the medical record.
Not so fast: But the final rule does not change the standard in the CMS Hospital CoP requirements mandating that an individual becomes an inpatient when formally admitted under an order for inpatient admission by a physician or other qualified practitioner (also referred to as the “2-Midnight Rule”). The final rule’s revision to admission orders also does not affect the requirements relating to which practitioners may issue inpatient admission orders.
The inpatient admission order effectively initiates the inpatient hospital admission for the purpose of 2-Midnight Rule compliance, noted The Health Law Partners (THLP). In general, an inpatient admission is appropriate for Medicare Part A payment when the admitting physician expects the patient to require hospital care that crosses two midnights.
Caveat: But this rule change doesn’t mean that your hospital doesn’t need to document inpatient admission orders at all. Although CMS removed the admission order documentation requirement as a condition of Part A payment, “an inpatient hospital admission order is still relevant and necessary,” THLP cautioned.
Don’t Become Too Lax, Though
Not everyone sees the change in CMS Hospital CoP requirements as entirely helpful to providers, however.
“While this guidance would appear to remove one technical basis for denials, it does not remove the need for evidence that a physician judged a patient in need of inpatient services,” stated Baker Donelson PC. “CMS continues to require that an inpatient be formally admitted as an inpatient to qualify for inpatient benefits covered under Part A.”
Reasoning: In the 2019 Hospital CoP final rule, CMS explained that it didn’t intend the inpatient order documentation requirements “should by themselves lead to the denial of payment for medically reasonable and necessary inpatient stays.”
Since CMS adopted the admission order documentation requirements related to the 2-Midnight Rule in 2013, hospitals have been denied Part A payments for medically necessary inpatient admissions due to technical discrepancies with documentation, Baker Donelson lamented. CMS changed the documentation requirements so that hospitals would no longer face erroneous payment denials due to occasional inadvertent issues, such as missing practitioner admission signatures, co-signatures and authentication signatures, and signatures occurring after discharge.
Tighten Up Your Documentation
Key takeaway: This documentation change doesn’t mean that you shouldn’t document the inpatient admission order, however. An inpatient admission order is still your hospital’s best documentation of a physician’s intent for an inpatient stay and “requiring physicians to continue to comply with such a rule would be a best practice from a compliance and reimbursement perspective,” Baker Donelson stressed.
Bottom line: Proper and thorough documentation helps you to avoid allegations of malpractice and substandard care, as well as accreditation problems and reimbursement denials, Sue Dill Calloway says in her webinar. So make sure you stay current on any and all changes to documentation mandates in the CMS Hospital CoP requirements.
