2-Midnight Rule – Appeal Status
We have been asked by several of our clients whether the 2-Midnight rule is dead now that CMS has made adjustments to the current PPS base rate increases to reverse the effects of the past implementation of the 2-Midnight rule. After review of the issue and follow-up with our legal counsel, we are continuing to pursue the issue as we believe that there are additional reimbursements to be recovered not reflected in CMS’ changes in the FY2017 final rules.
Our plan for clients in our groups is to continue pursuing this issue. We will keep you appraised as this issue progresses.