Lessons Learned from the Two-Midnight Rule: Compliance Tips for Short Stay Claims Reviews

Jennifer Kirchner | September 2014

Over the past year, there has been a growing controversy over the impact the Two-Midnight Rule will have on hospitals and providers. Since first set forth in the fiscal year (FY) 2014 Inpatient Prospective Payment System (IPPS) final rule, the rule has been delayed twice.  The Centers for Medicare & Medicaid Services CMS) has issued numerous guidance documents to help industry interpret the convoluted rule.  The American Hospital Association and other industry lobbyists have filed lawsuits against CMS to curb implementation of the rule.

About the Author

Jennifer Kirchner is a licensed attorney in Illinois and Wisconsin. Ms. Kirchner has expertise in assessing provider compliance with the Anti-Kickback Statute, Stark Law, the False Claims Act, HIPAA Privacy and Security Rules and clinical research laws and regulations.