Important things to keep in mind when implementing CMS 2-midnight rules effective October 1, 2014. Use this checklist when updating hospital policy and procedures, educating staff, senior level executives or physicians as needed.

  • Please make sure that the paper order or EHR order for inpatient status is matching with the billing system and the bill sent to CMS. Some hospitals have billing system different than the actual EHR used for physician orders and documentation.  Those who still use paper charting the same rules apply.
  • Physician or credentialed person ordering the inpatient or certifying the 2-midnight is a good start but it is not sufficient to secure payment if there is not sufficient documentation to support medical necessity.
  • It is important to have the signed order and sufficient documentation to support medical necessity to support for inpatient level of care. It should be signed off before the patient is discharged.
  • If patient recovers before two midnights then it is important to have clear documentation explaining the early recovery from the physician and not just a note that patient recovered earlier than expected.
  • We have prepared a short slide presentation. Please refer to the link Hospital Case Management CMS 2-Midnight Rules