Inpatient Facility Coding & Compliance Alert

Question: A patient is seen in the ER and admitted to observation on 6/11/2014 at 1:00 p.m. Patient is also seen as an observation patient on 6/12/2014 at 1:00 p.m. Patient is admitted on 6/13/2014 after two midnights. Patient had subsequent visits on dates 6/14/2014 and 6/15/2014. He was discharged on 6/16/2014. Please advise whether this meets the two midnight benchmark.

Minnesota Subscriber

Answer: The time the patient spent as an outpatient before being formally admitted as an inpatient definitely cannot be considered inpatient time. However, this can be considered for analysis whether the patient met the two-midnight benchmark and whether the payment for admission can be filed under Medicare Part A.

For this purpose, the review contractor will count the medically necessary services provided to the patient such as observation services and treatment in the ED as an outpatient prior to the inpatient admission.

Remember that the beginning point for the two midnight timeframe is when the patient actually starts receiving medically necessary services after he has reached the hospital. 

This should not include wait time prior to the patient being attended. Therefore, a patient sitting outside the ED at midnight while waiting for his turn to be attended will not be considered, but if he receives services in the ED during midnight, he would accrue the first midnight of the benchmark.