The “2 Midnight Rule” for hospital inpatient admissions certainly caused its fair share of confusion with providers in 2013. MLN Connects held a provider call on January 14th, 2014, “Inpatient Admission and Medical Review Criteria” to provide clarification to providers. As those of us in the long term care community are also concerned since this can impact the eligibility of a beneficiary’s stay at a post-acute or LTC facility, we decided to get some more details to see if CMS added any additional info to how the time is calculated.
On a recent Open Door Forum call, CMS clarified information on how the 2 Midnight Rule is calculated. The speaker on the MLN Connects call noted that the 2-midnight benchmark “clock” starts when hospital care begins. This includes observation care, emergency department, operating room and other treatment areas. The “basic rule” is that the start of care is after registration and initial triaging activities have started. Excessive wait times for care should not be included in the qualifying hours. The presentation also included several hypothetical examples to help hospital providers with identifying situations that may be confusing under the 2 Midnight Rule and information on how services will or will not qualify. To view the presentation, “Inpatient Admission and Medical Review Criteria,” visit the CMS website.