As previously reported, the final FY 2014 Medicare inpatient prospective payment system (IPPS) rule established new criteria for determining the appropriateness of inpatient admissions. In brief, under this policy, CMS generally will presume that surgical procedures, diagnostic tests, and other treatments are appropriate for Medicare Part A inpatient hospital payment when the physician admits a patient based on the expectation that the patient will require a stay of at least two midnights. On September 5, 2013, CMS released guidance on admission order and certification requirements in connection with the new "two ‐ midnight" benchmark. The guidance addresses standards for physician certification of hospital services, such as content, timing, authorization, and the medical record elements that meet the initial inpatient certification requirements. CMS also provides guidance on practitioner orders, including content, qualifications of ordering/admitting practitioner, verbal orders, "knowledge of the patient," timing, and specificity of the order.

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