The proposed rule would presume the admission was reasonable and necessary if the patient spent two midnights at the hospital or received a service on the inpatient-only list. ACS responded that the “proposed rule fails to address the difficulty that physicians face in determining whether a patient should be designated as an inpatient or on observation at the time of decision making.”
The organization requested a delay to finalizing the proposed rule to include labor and delivery days in the calculation of hospital Medicare use “because it may decrease graduate medical education payments to hospitals.”
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