On July 6, CMS released the Hospital Outpatient Prospective Payment System update proposed rule. The American Health Care Association (AHCA) has long been interacting with CMS regarding the increasing use by hospitals of Observation Stays that many times bar a patient from meeting the 3-day Qualifying Inpatient Stay necessary for admission into a SNF. Hospitals increasing use of Observation Stays is mainly due to hospitals' fears that inpatient stays may be later denied as medically unnecessary.
This proposed rule has been posted at http://www.ofr.gov/OFRUpload/OFRData/2012-16813_PI.pdf . It is over 600 pages long and still available only in the display copy. However, an excerpt of the observation stay issue is available in the Member's Only section of IHCA's website.
AHCA will submit comprehensive comments on the current system, the inclusion of observation days in the calculation of the 3-day stay, and other issues and potential improvements. Comments are due to CMS by September 4, 2012. If you would like to submit comments for AHCA's use, please send them to Zach Cattell at zcattell@ihca.org, and Zach will collate IHCA comments and get them to AHCA. AHCA is requesting that all member comments be sent to them by August 10 to insure timely inclusion of all comments.
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