News: CMS revises 2-midnight audit process
CMS changed its selection process for medical records for short-stay reviews under the 2-midnight rule. This could be problematic for some organizations, says Ronald Hirsch, MD, FACP, CHCQM, vice president at R1 Physician Advisory Services in Chicago, according to Revenue Cycle Advisor.
The update (which popped up on the Keystone Peer Review Organization (KEPRO) website at the end of March) states the following:
“CMS is changing the selection process for medical records for short-stay reviews. Previously, smaller providers had a request for 10 cases, and larger institutions had a request for 25 cases. As of April 2017, this process changed. CMS will sample the top 175 providers with a high or increasing number of short-stay claims per area with a request for 25 cases, and all other providers previously identified as having ‘major concerns’ in the prior round of review will have a request for 10 cases.”
KEPRO is one of the Beneficiary and Family Centered Care Quality Improvement Organizations (BFCC-QIO) reviewing 2-midnight compliance for the government. Prior to this change, BFCC-QIOs requested either 10 or 25 charts per hospital. The BFCC-QIOs would classify their results based on the number of denials as minor, moderate, or major concerns. Hospitals could choose to appeal some or all denials through interactions with the BFCC-QIO.
The original plan was for the BFCC-QIOs to do a second round of audits, says Hirsch. The results of those audits would have been used to refer some organizations for further auditing by the Recovery Auditors.
The notice from KEPRO changed this. In effect, it cancelled this second group of audits, says Hirsch. Instead, the BFCC-QIOs will now only perform audits on certain hospitals.
These hospitals include the following:
- Those that received “major concern” ratings in the first round of audits
- An additional list of 175 hospitals per region that had the highest number of short, inpatient admissions
Even if a hospital doesn’t make either of the lists, don’t expect to be audit free, says Hirsch. CMS specifically states that no hospital will be “free from audits.” Now is not the time to slack off on 2-midnight compliance and internal audits.
In fact, this change should prompt organizations to be even more diligent than in the past, says Hirsch.
“With the old audit plan, each hospital would have reviews every six months, and would get ongoing feedback on their performance, and would be able to see trends of increasing number of potential denials,” he says.
Under this change, organizations will get no warning if trouble is brewing.
“If you make the list, you are going to get a 25-chart audit and there is a lot at stake with those results,” Hirsch says. “So, hospitals need to keep a closer eye internally on their number of short-stay inpatient admissions and perform more internal audits if they start to increase.”
Editor’s note: This article originally appeared in Revenue Cycle Advisor. To view Hirsch’s 2017 conference presentation on Medicare updates, click here. To listen to an episode of ACDIS Radio featuring Hirsch, click here.