CMS Imposes Limit to Look-Back Period for Two-Midnight Reviews
CMS has announced that it has clarified the instructions for medical review of claims affected by the temporary suspension of the BFCC-QIO claim audits under the two-midnight inpatient admissions rule. Specifically, CMS announced that these reviews will be limited to a six-month look-back period from the date of admission. Per CMS, Medicare Fee-For-Service (FFS) claims that:
- Are outside the six-month look-back period and were formally denied (as defined below) are being removed from the provider sample for re-review and will be paid under Part A.
- Are outside the six-month look-back period and were not formally denied are being removed from the provider sample for re-review and will be paid under Part A.
- Are within the six-month look-back period and were not formally denied will be reviewed when we resume QIO reviews as per our sub-regulatory guidance.
- Are within the six-month look-back period and were formally denied are being re-reviewed by the BFCC-QIO to determine whether the initial review decision was consistent with the two-midnight policy in effect at the time of the hospital admission.
The imposition of the six-month look-back period is to help ensure that providers receiving denials for Part A claims have sufficient time to rebill under Medicare Part B.