All inpatient status orders must be signed prior to patient discharge

Dear Physicians,

When the Centers for Medicare and Medicaid Services (CMS) first revealed potential changes to requirements for the inpatient status order, it sounded as though relief was coming with 2019 IPPS rule changes.

CMS stated that it “had never intended” for auditors to deny claims based solely on a deficiency in the inpatient order and were proposing to remove the inpatient order as a condition for payment under Medicare Part A. Unfortunately in the final rule, CMS retained the language requiring a physician to sign the inpatient order prior to the patient leaving the hospital. The Medicare Benefit Policy Manual Chapter 1, Section 10(B) still reads “if the order is not properly documented in the medical record prior to discharge, the hospital should not submit a claim for Part A payment.”

The proposed and final 2019 IPPS rules indicate that the change in approach to the status order affects only the review process of auditors.  In the past, the agency that reviews Part A medical records for inpatient medical necessity (QIO) looked at the status order first to determine if it were a valid order according to CMS, signed by a physician prior to the patient leaving the hospital. If the order were not valid, they denied the claim even when they agreed with the medical necessity of the service.

Now the QIO will approach medical record documentation first and cannot deny an encounter solely on the basis of a deficient status order. However, everything else about the record must meet the QIO’s expectation of medical necessity for the claim to be paid.  If the QIO denies medical necessity, they will also review the status order and can cite RSFH for any deficiency in that order as well as deny the medical necessity claim.

What this means for you: RSFH policy regarding inpatient status orders will not change. It is expected that all inpatient status orders will be signed (or cosigned) by the physician prior to the patient being discharged from the hospital. Your utilization review staff is working very hard to validate each status order and to follow up with you if the order is not complete. We greatly appreciate your working with them to get this right for our patients.

Thanks for all you do.

Dr. Lou Applebaum

Chief Physician Advisor

Roper St. Francis Healthcare

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