Effective September 12, 2016, Beneficiary and Family Centered
Care (BFCC) Quality Improvement Organizations (QIOs) resumed their
hospital initial patient status reviews. The purpose of these
reviews is to determine the appropriateness of Medicare Part A
payments for short stays in acute care inpatient hospitals,
long-term care hospitals, and inpatient psychiatric facilities.
Originally, the BFCC-QIOs conducted initial patient status
reviews for short stay inpatient hospital claims on October 1,
2015. However, the Centers for Medicare and Medicaid Services (CMS)
suspended these reviews on May 4, 2016 after learning about the
BFCC-QIOs' inconsistent application of the two-midnight policy.
The purpose of the suspension was to allow time to promote the
consistent application of the medical review of patient status for
short hospital stays and to improve standardization in the
BFCC-QIOs' review process.
CMS ended the suspension on September 12 and reinstated these
The BFCC-QIOs have completed
re-training on the two-midnight policy;
The BFCC-QIOs have completed the
re-review of claims that were previously formally denied;
CMS has examined and validated the
BFCC-QIOs peer review activities related to short stay reviews;
The BFCC-QIOs have performed provider
outreach on affected claims and the two-midnight policy.
During the suspension, CMS made no changes to its guidance for
the BFCC-QIOs regarding these reviews. The guidance,
"Reviewing Short Stay Hospital Claims for Patient Status:
Admissions On or After January 1, 2016," can be found at: CMS.gov. CMS will continue to monitor this
area by reviewing a sample of BFCC-QIO completed reviews every
month, monitoring provider education calls, and responding to
individual provider questions.
In addition to the resumption of the BFCC-QIO reviews, Medicare
providers may also notice a corresponding increase in Recovery
Audit Contractor activity. The BFCC-QIOs can refer providers that
demonstrate persistent noncompliance with Medicare payment policies
to Recovery Auditors. As the BFCC-QIOs' reviews increase, there
is the potential that referrals to Recovery Auditors will increase
also. Medicare providers should continue to audit and monitor their
operations to ensure compliance with the Medicare 2-day stay and
observation status requirements.
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about your specific circumstances.
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