CMS Clarifies Regulations on Hospital Inpatient Admission Orders and Certifications

Date posted: October 8, 2013

The Centers for Medicare & Medicaid Services (CMS) released regulatory guidance on hospital inpatient admission orders and certifications.  The guidance interprets the Hospital Inpatient Prospective Payment System (IPPS) 2014 final rule, which outlines specific requirements for inpatient admissions.  According to the final rule, hospital inpatient admissions that span at least two midnights presumptively qualify as appropriate under Medicare Part A.

CMS clarifies that the physician certification, which includes the practitioner order, along with other documentation in the patient’s medical record, is considered evidence that hospital inpatient services were reasonable and necessary.  The certification begins with the order for inpatient admission and must be completed, signed, dated and documented in the medical record prior to discharge.  CMS requires certifications to be signed by the physician responsible for the case, or by another physician who has knowledge of the case and who is authorized to do so by the responsible physician or by the hospital’s medical staff.

During the final rule implementation period of October 1, 2013 until December 31, 2013, CMS has instructed Medicare Administrative Contractors and Recovery Audit Contractors to not review claims spanning more than two midnights after admission for appropriateness of patient status.

The CMS Guidance “Hospital Inpatient Admission Order and Certification” is available by clicking here.

The CMS “frequently asked questions” guidance is available by clicking here.


Centers for Medicare & Medicaid Services.  “Hospital Inpatient Admission Order and Certification.”  Guidance.  5 Sep. 2013.

Centers for Medicare & Medicaid Services.  “Frequently Asked Questions: 2 Midnight Inpatient Admission Guidance & Patient Status Reviews for Admission on or after October 1, 2013.”  24 Sep. 2013.

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