http://www.nhpco.org/sites/default/files/public/regulatory/GIP_Tip_GIP_Sheet.pdf The key issue, could the care be just as easily provided in another setting, such as a nursing home? If so, you're on thin ice. Other factors, how long were they out of control and how long have symptoms been managed? What interventions, and at what frequency, were necessary to get the patient to a comfortable state. Just because they are now comfortable doesn't mean they have to come off GIP if its taken incredibly hard work to keep them at that comfortable state. There is no specified number of days but since its expected to be short term, each additional day increases the risk of scrutiny. Each and every day, even the first, should have documentation to justify this level of care and answer the why here question.