EDPMA Comments on Alternative Payment Methodology for Short Hospital Stays and the Two-Midnight Rule


Today EDPMA filed these comments with CMS regarding its proposed rule on the 2015 Update to the Inpatient Prospective Payment System (IPPS).  The ACOEP agreed to cosign our letter.  CMS admits that the two-midnight rule has met with a great deal of criticism and sought comment on how to develop an alternative payment methodology for short hospital stays.  EDPMA’s letter provides a list of general principles that CMS should follow when developing a payment methodology for short stays.  For instance, “Payment for the stay should be based on the patients’ acuity, the severity of the patient’s illness or condition, and/or the intensity of services and resources required to treat the patient.”   It should “avoid setting arbitrary time-bound standards”  that lead to inconsistent application and a large number of unjustified audits.  EDPMA also encouraged CMS to acknowledge the essential role of the emergency physician in the short stay and develop physician reimbursement incentives that align with inpatient reimbursement policy. 

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