Two Midnight Rule

I am an acute care CM and I work for 2 different hospitals per diem. Each hospital is interpreting the 2 MN rule differently. One hospital is extremely strict and requiring a Medicare Attestation order upon admission, as well as documentation in the H&P clearly stating why this patient is expected to stay in the hospital for 2 midnights. If these 2 components are not met, the physicians are contacted by the CM to complete these in the medical record. They were not happy at first, but are starting to come on board.

The other hospital I work at is the complete opposite. They are interpreting the 2 MN rule completely differently. They are just expecting everyone to be inpatient if they stay 2 midnights, but I think that hospital will be in trouble when the RACs come around!

I too work for two hospitals. Neither hospital has had trouble with compliance because they take every new rule by CMS seriously. Doctors are either on board where I work or he/she is talked to by the head of Medical. CMs/UR nurses in my case are there to support MDs and DOs with information to assist him/her with admission status decisions. In fact, I think the 2 midnight rule has made my job a lot easier because I get less eye-rolling and push back about status. The only thing that has increased are the number of secondary reviews (both hospitals now added secondary reviews to protocol to cover the organization in cases that contradict Interqual criteria but are in-line with the 2 midnight rule).