Wednesday, September 2, 2015

Members of National Observation Stays Coalition Send Comment Letter to CMS

Dana Halvorson

Twenty-two members of the national observation stays Coalition sent a letter to the Centers for Medicare and Medicaid Services (CMS) earlier this week on the issue of the observation status. The comment letter was in response to a proposed rule on the annual update to Medicare reimbursement of outpatient care at acute care hospitals, and included proposed revisions to the “two-midnight rule.” Specifically, the Coalition encouraged CMS to fix one of the unintended negative consequences for beneficiaries of the in-patient vs. out-patient payment dilemma, by promulgating new rules that would count all time spent by a patient in the hospital, for purposes of satisfying the three-midnight rule for Medicare Part A coverage of post-acute care in a skilled nursing facility (SNF). 

The letter also specifically notes the Coalition’s support of federal legislation that would count all time spent by a patient receiving outpatient observation services in the hospital for purposes of satisfying Medicare’s three-midnight rule for SNF coverage. The identical bipartisan bills are H.R.1571 and S.843, the Improving Access to Medicare Coverage Act of 2015. For more information about the observation stays issue, please visit the AHCA/NCAL website.  

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