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AAMC Again Asks CMS to Delay New Inpatient Admission Criteria

September 20, 2013—The AAMC Sept. 13 requested  for a second time that the Centers for Medicare and Medicaid Services (CMS) delay for six months enforcement of the Admission and Medical Review Criteria for Hospital Inpatient Services Under Medicare Part A (also referred to as the “2 Midnight Rule”), which was finalized in the FY 2014 Inpatient Prospective Payment System rule [see Washington Highlights, Aug. 9]. Without a delay, the requirements will be effective Oct. 1, 2013.

The AAMC letter urges a delay because: 

  • More guidance is needed;
  • It is not possible to comply with the new requirements with less than one month between the issuance of the September guidance and the Oct. 1 effective date; and
  • Electronic health record (EHR) vendors will not be able to make the necessary changes to their systems by Oct. 1.

The letter also notes the need for flexibility for certain one-night stays, saying that “the payment system must be sufficiently flexible to adequately reimburse care that does not meet a bright line test but is medically necessary in the setting in which it is provided.”


Ivy Baer, J.D., M.P.H.
Senior Director and Regulatory Counsel
Telephone: 202-828-0499


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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

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Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806