ICD10monitor June 19, 2024
Juliet Ugarte Hopkins, MD

It has nearly been six months since 42 CFR 422.101(b)(2) within the Code of Federal Regulations was officially set into motion on Jan. 1, obligating Medicare Advantage (MA) plans to follow the Medicare Two-Midnight Rule and Medicare Inpatient-Only (IPO) lists when it comes to patient status.

Have all the postulated outcomes come to fruition? Hardly. Let’s consider two of them:

  1. Denials from MA plans for inpatient-designated hospitalizations will drop precipitously.
  • This most certainly has not happened, even anecdotally, because the Two-Midnight Rule does not simply involve passage of a second midnight in the hospital. It involves medical necessity of that second midnight. As much as it seems we have been talking about medical necessity since October 2013,...

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