Home Health & Hospice Week

Watch out for changes to the therapy reimbursement requests you get from hospitals. The Centers for Medicare & Medicaid Services has finalized the so-called "2 midnights rule" that encourages hospitals to have appropriate-length observation stays and inpatient stays.

By focusing medical review on long observation stays and short inpatient stays, CMS may change hospitals’ therapy billing patterns, suggests the National Association for Home Care & Hos-pice in its member newsletter. For example, a hospital with long observation stays may curtail them, resulting in fewer outpatient therapy services that are bundled into a home health plan of care. That, in turn, will mean fewer requests for you to pay for the hospital therapy, NAHC offers.

But if a hospital has very short inpatient stays, it may convert some of those to observation stays, increasing your requests for Part B therapy reimbursement from the facility. However, "agencies are not required to reimburse the facility for bundled therapy if there is no arrangement with the facility to provide the service," the trade group stresses.

OASIS consideration: "Agencies will most likely be required to complete the transfer/ [Resumption of Care] OASIS if the patient’s status is changed from observation to inpatient," NAHC advises. But "a transfer/ROC OASIS is only required if the inpatient status is greater 24 hours."