CMS recently provided an update on its education and enforcement strategies related to its "Two Midnight" policy, which addresses when surgical procedures, diagnostic tests and other treatments are generally considered appropriate for inpatient hospital admission under Medicare Part A. The Medicare Access and CHIP Reauthorization Act of 2015 generally bars recovery audit contractors (RACs) from conducting post-payment patient status reviews related to this policy until October 1, 2015. On August 12, 2015, CMS announced that it is extending this moratorium on inpatient status reviews to apply to dates of admission of October 1, 2015 through December 31, 2015. CMS also set forth the responsibilities of Quality Improvement Organizations, Medicare Administrative Contractors, and RACs for various types of patient status reviews and the timeline for such reviews.
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