The 2 midnight rule is designed to identify the appropriate level of care for short term stays or episodes in acute care, critical access and long term hospitals and to reimburse accordingly. The rule designed to save money by payment through Medicare part B instead of A is seen by many consumers and providers as both unclear and a cost shift from CMS to consumers and providers hence the controversy surrounding this rule. The presentation will provide history, explanation of the rule with both medical and financial outcomes and illustrate with case examples.
The presentation opens with an explanation and interpretation of the rule and includes exceptions. It explains the reason for the midnight designation based on the use of the midnight census to determine length of stay and provides an example of the calculation.
A discussion of the goal of the rule and questions about whether it has been achieved
A description of Medicare Parts A and B payment follows. History is then provided for context – why and how the rule developed including precursors of length of stay reduction and the move from in patient to ambulatory care as well as cast savings objectives.
Current requirements surrounding the Rule.
Role of the Case Manager in the ED.
Billing issues, Condition 44 code, billing for observation including criteria
Financial outcomes/implications of the rule for CMS, providers and consumers.
Example of costs to provider – code requirements for an observation unit in California
Medical outcomes of the Rule – quality of care, ability to obtain covered continued skilled care Case examples of observation vs inpatient
Controversy over the bill from cost shifting and consumer rights issues to quality of care concerns to the ability to truly differentiate status. Has the bill achieved its goals?
The purpose of this program is to familiarize the learner with an understanding of the 2 midnight rule as it applies to implementation within a facility including criteria and requirements. The financial outcomes of the rule both intended and unintended will be resented.
Attendees will be able to explain and interpret the 2 midnight rule
An understanding of the intent and interpretation of the rule will aide the participant in implementing a program to comply with the rule and if implemented can be used to review current practice for compliance. Having a historical context for the rule makes it easier to understand the strategy and anticipate governmental requirements.
The rule remains controversial with consumers and providers. Implementation of the MOON as well as staff training can mitigate misunderstanding and help to manage consumer expectations surrounding their care and its costs.
A general understanding of billing issues will be provided but this is not a billing specific program which is a specialized area requiring a separate webinar.Areas Covered in the Webinar:
President, NYC chapter of CMSA
Laura Ostrowsky RN, CCM MUP is the current president of the NYC chapter of CMSA and a Director on the national CMSA board. She teaches a CCM prep course with the Case Management Institute, works with Athena Forum, and writes andconsults on case management and related topics. Laura has published articles on Case Management in CMSA Today, Professional Case Management, Case in Point, The Patient Flow Journal and other periodicals. She regularly presents at national conferences including CMSA, the Patient Advocate Institute, NTOCC and others on topics ranging from case management, patient flow and payer provider collaboration to advocacy, collaborative practice and case management’s role in the changing health care environment.
Laura is a past Director of Case Management at Memorial Sloan-Kettering Cancer Center (1999-2019) and the 2012 CMSA Case Manager of the Year. Her program was been nominated by Case in Point for excellence in Utilization Management, Discharge Planning and Transitions in Care and awarded the patient Advocate Award. She created a patient advocacy program to assist patients in obtaining access to specialty care despite network restrictions. The program has been featured in articles in Advance for Nursing, The Wall Street Journal, Case in Point, and Case Management Monthly.
Laura holds a master’s degree in Health Planning and Policy from Hunter College.
Laura has 40 years of health care experience, including time as a staff nurse, QA Coordinator, Director of UR and QA, followed by directorships in CM at New York Presbyterian (NYP) and Memorial Sloan Kettering Cancer Center and providing educational presentations as part of the Genentech Speaker’s Bureau.
The Two Midnight Rule has been in effect since October 1, 2013 with updates for implementation since October 30, 2015. However it has been controversial from the beginning.
Registrants may cancel up to two working days prior to the course start date and will receive a letter of credit to be used towards a future course up to one year from date of issuance. FDATrainingAlert would process/provide refund if the Live Webinar has been cancelled. The attendee could choose between the recorded version of the webinar or refund for any cancelled webinar. Refunds will not be given to participants who do not show up for the webinar. On-Demand Recordings can be requested in exchange.
Webinar may be cancelled due to lack of enrolment or unavoidable factors. Registrants will be notified 24hours in advance if a cancellation occurs. Substitutions can happen any time.
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