SOP # PATIENT STATUS ASSIGNMENT Revision # Implementation Date Page # _____ of _____ SOP Owner Last Reviewed/Update Date Approval Standard Operating Procedure 1. Purpose To require that the hospital obtain appropriate patient status orders and certification for Medicare inpatient admissions. 2. Scope All hospital staff performing and/or billing Medicare inpatient and/or outpatient services: acute care staff, employed physicians and their office staff; and all affiliated physicians. 3. Policy The Centers for Medicare and Medicaid Services (CMS) have established a two-midnight benchmark for inpatient status effective October 1, 2013. At the time the physician determines the patient will need hospital care, and anticipates that the patient will stay at least two midnights, the physician should complete an order for inpatient admission. If a patient is expected to stay less than two midnights at the time the physician determines the patient will need hospital care, the physician should complete an order for outpatient observation. Medicare has a list of procedures by CPT code, also known as Addendum E, that is considered to be inpatient only. If a patient is to receive a procedure on this list, the SOP # PATIENT STATUS ASSIGNMENT Revision # Implementation Date Page # _____ of _____ SOP Owner Last Reviewed/Update Date Approval physician should admit the patient as an inpatient regardless of the expected length of stay. CMS requires that the physician order must be present in the medical record and be supported by the physician admission and progress notes in order for the hospital to be paid for hospital inpatient services under Medicare Part A. In addition, the admission must be certified by the physician. Collectively, these requirements are necessary to support inpatient admission. 5. Procedure 1. The hospital CEO shall provide oversight and the hospital CFO is responsible for implementation of this policy. 2. The hospital must utilize the approved medical record format (Insert here what you have decided for the hospital to use for admission orders i.e. forms or EMR formats) for all Medicare patients who need a bed for continuing hospital care. It must be used for the initial patient status order as well as any subsequent patient status orders. 3. A Medicare patient is considered an inpatient of a hospital if formally admitted as an inpatient on an order for inpatient admission by a physician or other qualified practitioner. The physician’s inpatient admission order: 1. Must be obtained at admission. 2. Must be supported by the physician admission and progress notes. 3. Must be written by a physician who is knowledgeable about the patient’s hospital course, medical plan of care, and current condition at the time of admission. SOP # PATIENT STATUS ASSIGNMENT Revision # Implementation Date Page # _____ of _____ SOP Owner Last Reviewed/Update Date Approval 4. The physician’s certification of an inpatient admission begins with the order for admission. The certification must be completed, signed, dated and documented by the certifying physician prior to discharge. CMS requires specific content of the certification (see table below). Content Admission order authentication Reason inpatient services are medically required Estimated length of stay Post hospital care Requirement is Met By Signature or countersignature of certifying physician Diagnosis, inpatient admission assessment, plan of care, and/or orders Admission order written in accordance with two midnight benchmark, supplemented by physician notes and discharge planning instructions Discharge planning instructions 5. In addition to the admission order and certification, documentation by the physician in other areas of the medical record must be sufficient to support that inpatient hospital services were reasonable and necessary. The documentation can be present in the history and physical, progress notes and the discharge summary. The documentation must include: 1. Patient history and comorbidities; 2. Severity of signs and symptoms; 3. Risk of adverse events; and SOP # PATIENT STATUS ASSIGNMENT Revision # Implementation Date Page # _____ of _____ SOP Owner Last Reviewed/Update Date Approval 4. Current medical needs requiring inpatient care (e.g., frequent 2-4 hour monitoring, IV medication requiring hospitalization, high risk of possible infection, etc.). Hospital status is further explained below: Outpatient status When a physician expects a patient to need a bed for continuing hospital care for only a limited period of time that does not cross two midnights, the services would be generally appropriate as an outpatient including observation. When a patient presents with an undetermined diagnosis and it is difficult for the physician to determine how long the patient will stay, the physician should place the patient in outpatient status and order observation services. If a physician has ordered outpatient status with observation services and new information becomes available that suggests the patient will require hospital services a total of at least two midnights, the physician should reassess the patient and consider admission to inpatient status. Inpatient Status When a physician expects a patient to require a hospital stay that crosses at least two midnights, the services would be generally appropriate for inpatient admission. If the physician expects a two-midnight stay and orders inpatient admission, but the patient improves more rapidly than the physician’s reasonable, documented expectation, such cases may be billed as inpatient care. SOP # PATIENT STATUS ASSIGNMENT Revision # Implementation Date Page # _____ of _____ SOP Owner 6. Last Reviewed/Update Date Approval References 1. CMS-1599-F Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Proposed Fiscal Year 2014 Rates 2. 42 CFR 412.3 Admissions 3. 42 CFR 424, Subpart B – Certification and Plan Requirements 4. CMS Hospital Inpatient Admission Order and Certification dated 9/5/2013 6. Definitions Inpatient Status – generally, a Medicare patient who is expected to receive hospital services for at least two midnights; or a patient who receives services listed on Medicare Inpatient-Only list, also known as Addendum E. Outpatient Status – generally, a Medicare patient who is expected to receive hospital services for only a limited period of time that is not anticipated to cross two midnights this includes outpatients receiving observation services.