On April 24, 2018, the Centers for Medicare & Medicaid Services (CMS) released the Fiscal Year (FY) 2019 Inpatient Prospective Payment System (IPPS) Proposed Rule (CMS-1694-P). Among other changes, CMS proposes eliminating its regulatory requirement that a written inpatient admission order be present in the medical record as a specific condition of Medicare Part A payment. This is one of many changes that CMS has made or proposed over the last several years in connection with the Two Midnight Rule implementation and associated documentation requirements. Notably, although this proposal does not negate CMS’s policy that the medical record must support the inpatient admission, this proposal, if finalized, would likely reduce the denial of medically necessary inpatient admissions for reasons solely related to technical deficiencies in inpatient admission orders.

OVERVIEW OF INPATIENT ADMISSION ORDER REQUIREMENTS -

CMS implemented sweeping changes to its inpatient admission coverage standards and documentation requirements through the implementation of the Two Midnight Rule in the FY 2014 IPPS Final Rule (CMS 1599-R), effective October 1, 2013. One of those changes involved specific inpatient admission order requirements.