Premier, Inc.
By Blair Childs, senior vice president, Public Affairs, Premier

Members of the Premier healthcare alliance continue to have significant issues with CMS's proposed changes to the Two Midnight policy in the proposed Outpatient Prospective Payment System (OPPS) rule.

In particular, we remain troubled by the fact that CMS has offered no plans to do away with a 0.2 percent cut to inpatient payments as part of the Two Midnight policy. As we have stated in the past, CMS provided virtually no justification for these cuts that exacerbate the inadequate reimbursement reality facing hospitals under Medicare.

However, we do appreciate CMS's proposal to allow high-acuity patients to be admitted to the inpatient setting, even if their expected stay is less than two midnights, if the attending physician believes it medically necessary. This is an important shift in the policy, giving physicians decision-making authority over the best, most appropriate setting of care based on patient needs, rather than following an arbitrary timeline imposed by CMS.

Furthermore, CMS's plan to change their approach to educating providers and enforcing the Two Midnight rule by moving first-line medical reviews over to Quality Improvement Organizations (QIOs), as opposed to using Medicare Administrative Contractors (MACs) or Recovery Auditors (RACs) sends an important signal that CMS is willing to work collaboratively to ensure providers admit to the best setting of care. We appreciate that MACs and RACs will only focus on outlier providers, rather than jumping straight to punitive measures for all.

- Blair Childs, Senior Vice President, Public Affairs, Premier, Inc.

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