OIG Report: Two-Midnight Policy Led to Limited Access to Skilled Nursing Care

Dana Halvorson

On Monday, December 19, the Office of the Inspector General (OIG) released a report noting that the two-midnight policy led to limited access to skilled nursing care. This Medicare policy requires patients to be hospitalized for two midnights before they qualify as an inpatient, which can allow beneficiaries to qualify for skilled nursing facility (SNF) coverage. According to the OIG report, the policy increased the number of beneficiaries with hospital stays that did not qualify them for Medicare SNF coverage. The report follows up on previous OIG work and compares data from the year before and the year after the implementation of the two-midnight policy. The Centers for Medicare and Medicaid Services (CMS) implemented the two-midnight policy in fiscal year (FY) 2014.

OIG recommended the following in their report: “We recommend that CMS (1) conduct routine analysis of hospital billing and target for review the hospitals with high or increasing numbers of short inpatient stays that are potentially inappropriate under the 2-midnight policy; (2) identify and target for review the short inpatient stays that are potentially inappropriate under the 2-midnight policy; (3) analyze the potential impacts of counting time spent as an outpatient toward the 3-night requirement for SNF services so that beneficiaries receiving similar hospital care have similar access to these services; and (4) explore ways of protecting beneficiaries in outpatient stays from paying more than they would have paid as inpatients. CMS concurred with all four recommendations.” You can read the full report and its findings here.

The McKnight’s article on this report can be found here

 

 

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