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Three Day Payment Window

It seems as though Medicare’s new three-day payment window explanation will clear the air regarding how to properly bill for inpatient stays. President Obama signed the Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010 into law on June 25, 2010. As part of the new law, “hospitals should bill as part of the inpatient stay all non-diagnostic services provided on the day of admission as well as those in the three days prior to admission unless they can demonstrate that the services are unrelated to the admission.” CMS has stated that they plan on issuing guidelines for hospitals on how to bill for these services.

If a hospital thinks that a service provided to an inpatient within the three-day payment window is unrelated to their current stay, they may bill separately for this service but not without proper documentation. Even with the proper documentation, hospitals may be targeted for further investigation into the case.

Concerns have arisen due to the fact that this process will demand more time and resources to ensure CMS compliance. Hospitals believe they might have to have an employee reviewing all services provided within three days prior to an inpatient admission. However, the government has suggested that hospitals carefully read the latest press release regarding the three-day window on billing practices until further clarification is provided.

From this point forward, hospitals will have to wait for CMS to explain the exact definition of “other related services.” Until that is provided, the previous definition should be applied. According to the Medicare Claims Processing Manual, services are considered related when there is an exact match for all digits of the ICD-9-CM principal diagnosis code for both the preadmission services and the inpatient stay.

The FTC said it hopes to begin enforcing the Red Flags Rule as soon as possible and will begin as soon as Congress acts on legislation, even if that action comes before December 31, 2010.

References:

Iarrobino, M, & Carroll, J. (2010, June 28). Hospitals face three-day payment window changes.