The “2 Midnight Rule” for hospital inpatient admissions has caused quite a bit 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. While much of this impacts Acute care facilities specifically (LTCH’S) There will undoubtedly be residual effects for our business model as well.
I’ve done some research on this topic as to how it would conceivably affect our admissions. On the surface of things, one might argue that a relaxation of the 3 night rule to eliminate a day, should be a boon for Skilled Nursing Facilities in that it would allow for increased opportunities.
However, I’m not sure I see it that way. The fact is, hospitals have ramped up the frequency by which they hold patients in the ER under observation and never admit, or they admit after a few days for a short window, which might preclude SNF’s from accepting under the 3 night rule. Theories as to why this is abound. Suffice it to say, it is not a simple mathematical formula and there are many nuances and permutations under consideration.
Still, I was encouraged by a recent Open Door Forum call, where CMS clarified information on how the 2 Midnight Rule is calculated. The speaker on the MLN 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.
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.