The American Hospital Association and the American Medical Association on Nov. 8 urged the Centers for Medicare & Medicaid Services to delay enforcement of its two-midnight policy for inpatient admission and review criteria until October 2014, and convene a meeting with affected stakeholders to develop alternate policy solutions.
“The fundamentally flawed, overly complicated two-midnight policy does not provide the clarity needed for consistent decision-making by either providers or reviewers,” the groups wrote. “…Moreover, it has been impossible for hospitals and physicians to come into compliance with the two-midnight policy given the two-month time period between the release of the final rule and the policy’s effective date. Even with the partial delay in enforcement through March 31, 2014, there is not enough time for hospitals and physicians to adjust.”
In particular, hospitals need additional time to reevaluate and potentially change many internal policies, update existing electronic medical records systems, and alter work flow processes to ensure compliance with the two-midnight policy, the letter notes. “Physicians will need extensive education on the two-midnight policy and time to adapt to its order and certification requirements, many of which are still unclear,” they add.