This past summer when the first Recovery Audit Contractor (RAC) approved the issue "inpatient admissions without a physician's inpatient admit order," it placed an impetus on hospitals to tighten up internal processes to avoid RAC audits and potential recoupments at their facility.
Recently, CMS released guidance on hospital inpatient admission decisions, that shows there is still confusion and room for improvement.
One seemingly prevalent hot-button issue is the date and time for an inpatient/observation admission to an acute-care facility. The admission date and time is determined by the physician's "admit to inpatient," order, but sometimes the correct course of action is not so clear.
For example,ifa physician makes the decision to "admit to inpatient" at 11 p.m. on January 1, 2011, the inpatient admission date would be 11 p.m. But if the patient is in the emergency room at this time and the order is written at 11 p.m. and the patient is not transferred until midnight, what is the proper time to document?
This is not an uncommon scenario according to Debbie Mackaman, RHIA, CHCO, regulatory specialist for HCPro, Inc., who suggests that when it comes to determining the proper course of action, providers should look toward CMS manuals for guidance, in particular the Medicare Claims Processing Manual, Chapter 3, § 40.2.2.
The manual says that a patient is considered an inpatient upon issuance of a written physician's order for inpatient care, and if the patient dies/is discharged prior to being assigned and/or occupying a room, the patient is still considered an inpatient on the date of admission and the hospital may charge for room and board, Mackaman says.