The Two Midnight Rule - Guidance, status and key steps on implementation to avoid enforcement difficulties

Why Should You Attend:

The ‘Two-Midnight Rule’ is now a condition of payment, not merely a condition of participation. This rule is continuing to generate confusion, with new guidance and adjustments being issued by CMS on a routine basis. Healthcare providers need to understand the key issues to focus on to protect their organizations from the new risks associated with this rule, and how non-compliance in this area can dovetail with ICD-10 non-compliance. These two areas may each have a devastating impact on revenue, once in effect and enforcement is active.

This presentation will provide the key steps in the assignment of patient status as well as the documentation necessary to satisfy the regulators. This presentation will also provide a better understanding of the ways that this rule can affect patients, in terms of their out-of-pocket responsibilities and eligibility for a stay in a skilled nursing facility.The presentation will outline best practices for minimizing financial risk to the hospital as well as the patients, and steps to take to avoid unnecessary government audits and reviews.

Areas Covered in the Webinar:

• An overview of the key elements of the ‘Two-Midnight Rule’
• An outline of criteria for observation versus inpatient admissions
• Key documentation requirements to correctly document patient status
• Enforcement activity and schedule
• How hospitals can comply and still get audited
• The potential impact of this rule on patients
• Best practices for meeting the ‘Two-Midnight Rule’ requirements

Who Will Benefit:

This webinar will provide valuable assistance to personnel in hospitals, academic medical centers, billing companies, IT vendors and consultants, specifically including:

• Compliance Directors/Officers
• CEO
• CFO
• Revenue Cycle Director
• HIM Director
• Billing Office
• Information Systems Manager
• Denials Prevention, Management, and Appeals Personnel
• Case Management
• Clinical Documentation Improvement Specialists
• Internal Audit
• Medical Staff
• Residents and Interns
• Healthcare Counsel/lawyer
• Emergency Department Personnel
• Admissions Office

Instructor Profile:

Susan Walberg, JD, MPA, CHC Susan has over 20 years’ experience in the healthcare field, both on the provider and the payer side. On the payer side, Susan’s experience includes medical underwriting, contract and benefit analysis, and Part B audits and investigations, both as desk and onsite audits. She worked for a number of years as a Regulatory Attorney and Privacy Officer for a very large multi-state health system, where she was responsible for the interpretation, analysis, and application/implementation of both state and federal laws (including HIPAA and the Deficit Reduction Act), as well as policy development and implementation. Susan also did a lot of work analyzing contracts to ensure compliance with Stark and Anti-Kickback requirements, and provided education to corporate and staff at the various entities on those topics as well as others. Susan was responsible for leading internal reviews and investigations, and directing overpayment situations. She collaborated closely with the business office, Information Security, Human Resources, Internal Audit, and other departments in order to ensure all impacted departments were fully aware in changing laws, policies, and enforcement activity. She was also involved in responding to privacy and security breaches, and helped develop the response process and related policies.

Susan has also worked as the Corporate Compliance Officer in two health systems, and managed the staff and facility compliance activities in those organizations, including developing Code of Conducts, conducting compliance program assessments, developing risk assessments, policies and procedures, board reports, education plans and tools, and Conflict of Interest processes. She had oversight of the physician documentation and coding team, and was responsible for assisting those activities as well as editing and presenting those reports, as needed, to the board and leadership. She provided analysis and consultations for questions related to fraud and abuse laws and operational requirements. She has worked in a teaching facility as the Interim Compliance Officer, developing and managing the Compliance Program in that organization and managing compliance incidents and government audits and investigations. She provided assistance in handling a self-disclosure as well as an accreditation review of the teaching program. She has both led and collaborated on attorney-client privileged audits and investigations, and has worked with a variety of regulators to response to their reviews. Most recently, Susan worked with a sub-contractor under CMS, providing support for fraud and abuse audits and policy analysis on Medicare Parts C and D.

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