OIG Issues Report on Medicare’s ‘2-Midnight Hospital Rule’

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On December 19, 2016, the US Department of Health and Human Services Office of Inspector General (OIG) posted a report examining the Centers for Medicare & Medicaid Services’ (CMS’s) “2-Midnight Rule.” The OIG concluded that although the number of inpatient stays decreased and the number of outpatient stays increased under the 2-Midnight Rule, Medicare paid nearly $2.9 billion in fiscal year 2014 for potentially inappropriate short inpatient stays. The OIG recommended that CMS improve oversight of hospital billing.

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Christine Parkins Johnson
Christine Parkins Johnson focuses her practice on complex regulatory and transactional counseling to health care organizations, such as health systems, hospitals, physician groups, long-term care facilities, pharmacies and other health care providers. Christine's regulatory practice focuses on health facility licensure and permits; Medicare and Medicaid enrollment; reimbursement and billing; survey/certification and accreditation; hospital governance and medical staff issues; and licensure under California's Knox Keene Act. Christine also has particular experience with hospital system and multi-state pharmacy changes in ownership. Christine's transactional practice is focused on joint ventures and mergers and acquisitions. Read Christine Parkins Johnson's full bio.

Emily J. Cook
Emily J. Cook provides counsel to health care providers on complex regulatory and reimbursement matters. Her regulatory experience includes fee-for-service Medicare and Medicaid reimbursement, billing and coding, licensure, survey/certification and accreditation, and compliance with Medicare and state fraud and abuse requirements. She also has significant experience counseling health care providers and other stakeholder entities on issues related to 340B drug pricing program implementation, compliance and advocacy. Read Emily J. Cook's full bio.

Sandra M. DiVarco
Sandra (Sandy) M. DiVarco focuses her practice on the representation of hospitals and health systems. She has counseled health care facility and system clients regarding all aspects of health law transactions and health system restructurings. Read Sandra DiVarco's full bio.