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Last Modified: 4/10/2024 Location: FL, PR, USVI Business: Part A, Part B

Checklist: Inpatient admission documentation

Two-midnight rule
On August 2, 2013, CMS issued Fiscal Year 2014 Inpatient Prospective Payment System (IPPS) final rule (CMS-1599-F), which modifies and clarifies CMS‘s longstanding policy on how Medicare contractors review inpatient hospital admissions for payment purposes.
The two-midnight presumption outlined in CMS-1599-F specifies hospital stays spanning two or more midnights after the beneficiary is formally admitted as an inpatient will be presumed to be reasonable and necessary for the inpatient status as long as the hospital stay is medically necessary. Inpatient stays spanning less than two midnights after the beneficiary is formally admitted as an inpatient are not subject to the presumption and may be selected for medical review. However, if total time in the hospital receiving medically necessary care (including pre-admission outpatient time from the time care is initiated in the hospital) spans two or more midnights, the two-midnight benchmark for inpatient admission will be met and payment supported upon medical review.
This checklist was created as a tool to assist hospital personnel when responding to medical record documentation requests. The provider of service must ensure correct submission of documentation to the Medicare contractor within the specified calendar days outlined in the request.
The documentation submitted for review should include, if applicable, but is not limited to the following:

Check
Documentation description
 
Name of beneficiary and date of service in all documentation
 
Inpatient certification:
Signed and dated by a physician prior to discharge
Reason for inpatient admission
Estimated and/or actual hospital time
Progress notes support the reason for admission and explain current treatment plans
Post-hospital care plans
Valid inpatient admission order
 
Admission order:
Includes specific language such as “admit to inpatient,” “admit to inpatient services,” or similar
Written order
Verbal order:
Includes specific language such as “admit to inpatient,” “admit to inpatient services,” or similar
Identity of the ordering physician/practitioner
Countersigned and dated by a physician/practitioner
Written at or before the time of the inpatient admission
Authenticated prior to discharge
 
Two-midnight benchmark:
Include all outpatient services time
Observation
Emergency department
Operating room
Other treatment areas
 
Exceptions or unforeseen circumstances:
Patient’s death
Patient transferred to another facility
Patient left against medical advice (AMA)
Unexpected recovery is clearly documented in medical record
Other
 
Signed, timed and dated physician orders for each day of care/service
 
History and physical
 
Legible physician progress notes
 
All diagnostic and laboratory reports, as applicable
 
Surgical procedure reports
 
Anesthesia reports
 
Medication administration record
 
Nurses' notes
 
Ambulance run sheet
 
Discharge summary
 
Signature log or physician’s attestation for any missing signatures
 
Signed ABN/HINN
 
Any other clinical records that support the medical necessity of the service billed
 
Any other documentation a provider deems necessary to support medical necessity of services billed, as well as documentation specifically requested in the letter
Disclaimer
This checklist was created as an aid to assist providers. This aid is not intended as a replacement for the documentation requirements published in national or local coverage determinations, or the CMS documentation guidelines. It is the responsibility of the provider of services to ensure the correct, complete, and thorough submission of documentation.
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