When is a Patient Not a Patient?

“Admit as inpatient” are probably the most valuable words written or electronically entered by physicians. And to be honest, I think the Centers for Medicare & Medicaid Services (CMS) has a little too much psychological and physical dependence on these words.

Is a patient any less a patient because those three words are not on the chart? I don’t think so. Does it cost a hospital less to care for a patient if those three words are not on the chart? I know that’s not true. And does something magically happen to a patient when they leave the hospital if they had those three words on the chart, but they were not authenticated prior to discharge? They sure look the same when they leave. Yet this phrase is seems to be viewed by CMS as being even more important than anything else that happens to the patient.

This came up two weeks ago when a physician advisor asked how to status a patient who came into the emergency department with a heart attack. During cardiac catheterization the patient rapidly decompensated and required the placement of an intra-aortic balloon pump to maintain circulation – and actually, to keep them alive. The patient then was rapidly transferred to a larger hospital for specialized care.

But those silly doctors, in their rush to save a life, did not stop to consult addendum E of the Outpatient Prospective Payment System (OPPS) Final Rule and see that an intra-aortic balloon pump is an inpatient-only surgery – and therefore, an inpatient admission order should have been written prior to the patient’s discharge.

As a result, the hospital is unable to bill for an inpatient admission; it must bill an outpatient stay and get paid a much lower outpatient rate for saving that patient’s life. In fact, since the patient underwent a cardiac catheterization and the balloon pump procedure, by outpatient bundling rules (only one SI = J1 procedure is paid), the hospital will get no money beyond the payment for the catheterization.

But can’t the hospital explain that the patient was dying, and patient care should come first? Well, that sounds good, but the example CMS gives for the extremely rare situation when billing with a missing or defective order is a patient who has emergent open-heart surgery and spends several days at the hospital – not the patient who never even gets to an inpatient bed, but underwent an inpatient-only surgery.

One case management director recently stated that his hospital’s write-offs of inpatient-only surgeries without admission orders is a constant problem, since the surgery booked by the surgeon and the actual surgery performed often differ just slightly and result in a new code and a different required status. And if that status was inpatient, the hospital is out of luck and gets no payment.

And why the requirement to authenticate a verbal admission order prior to discharge? That also has no logical explanation. The patient was formally admitted as inpatient, received inpatient care, and was discharged. Yet the lack of a simple signature potentially costs the hospital tens of thousands of dollars.

I can’t explain why these three words mean so much. I know it is outlined in the Social Security Act and federal regulations, and but it just feels good to be able to go on Monitor Mondays and suggest to CMS and Congress that they just get beyond it.

Facebook
Twitter
LinkedIn

Ronald Hirsch, MD, FACP, ACPA-C, CHCQM, CHRI

Ronald Hirsch, MD, is vice president of the Regulations and Education Group at R1 Physician Advisory Services. Dr. Hirsch’s career in medicine includes many clinical leadership roles at healthcare organizations ranging from acute-care hospitals and home health agencies to long-term care facilities and group medical practices. In addition to serving as a medical director of case management and medical necessity reviewer throughout his career, Dr. Hirsch has delivered numerous peer lectures on case management best practices and is a published author on the topic. He is a member of the Credentials Council and Government Affairs Committee of the American College of Physician Advisors, on the advisory board of the National Association of Healthcare Revenue Integrity, a member of the American Case Management Association, and a Fellow of the American College of Physicians. Dr. Hirsch is a member of the RACmonitor editorial board and is regular panelist on Monitor Mondays. The opinions expressed are those of the author and do not necessarily reflect the views, policies, or opinions of R1 RCM, Inc. or R1 Physician Advisory Services (R1 PAS).

Related Stories

Leave a Reply

Please log in to your account to comment on this article.

Featured Webcasts

AI, Audits, and the Future of the Revenue Cycle

Artificial intelligence is rapidly transforming healthcare revenue cycle operations, from coding and auditing to compliance and denials. Join industry leaders Pam Warren (MaineHealth) and Raemarie Jimenez (AAPC) for a live fireside chat exploring how AI is changing workflows, workforce roles, payer-provider dynamics, and compliance risk—and what organizations should be doing now to prepare.

June 17, 2026

Trending News

Featured Webcasts

Ask Dr. Hirsch: Clarifying Medicare’s Most Misunderstood Rules – Part 2

Medicare regulations are complex and even seasoned professionals struggle to apply them consistently. Due to overwhelming demand, Dr. Hirsch returns for Part 2 of Ask Dr. Hirsch: Clarifying Medicare’s Most Misunderstood Rules to answer even more of Medicare’s most misunderstood questions, covering inpatient status, observation, SNF access, Medicare Advantage denials, and more. Join Dr. Hirsch as he provides clear, referenced answers to real-world questions submitted by your peers, helping you navigate Medicare compliance with confidence and clarity.

June 18, 2026

Reengineering Utilization Management: Building an Adaptive Model for the New Payer Era

Traditional utilization management models can no longer keep pace with regulatory shifts, payer scrutiny, and operational pressures. In this webcast, Tiffany Ferguson, LMSW, CMAC, ACM, ACPA-C, introduces an Adaptive Model strategy that modernizes UM through role specialization, technology-driven workflows, and proactive, team-based processes. Attendees will learn how to restructure programs to improve efficiency, strengthen clinical collaboration, and enhance financial performance in a rapidly changing healthcare environment.

May 20, 2026

Compliance for the Inpatient Psychiatric Facility (IPF-PPS): Minimizing Federal Audit Findings by Strengthening Best Practices

Federal auditors are intensifying their focus on inpatient psychiatric facilities, using advanced data analytics to spotlight outliers and pursue high‑dollar repayments. In this high‑impact webcast, Michael Calahan, PA, MBA, Compliance Officer and V.P., Hospital & Physician Compliance, breaks down what regulators are really targeting in IPF-PPS admissions, documentation, treatment and discharge planning. Attendees will learn practical steps to tighten processes, avoid common audit triggers and protect reimbursement and reduce the risk of multimillion-dollar repayment demands.

April 9, 2026

Mastering MDM for Accurate Professional Fee Coding

In this timely session, Stacey Shillito, CDIP, CPMA, CCS, CCS-P, CPEDC, COPC, breaks down the complexities of Medical Decision Making (MDM) documentation so providers can confidently capture the true complexity of their care. Attendees will learn practical, efficient strategies to ensure documentation aligns with current E/M guidelines, supports accurate coding, and reduces audit risk, all without adding to charting time.

March 31, 2026

Trending News

Celebrate Lab Week with MedLearn! Sign up to win one year of our Laboratory All Access Pass! Click here to learn more →

Have a Medicare regulation question you’d love Dr. Hirsch to answer? Now is your chance! CLICK HERE to learn more→

Happy National Doctor’s Day! Learn how to get a complimentary webcast on ‘Decoding Social Admissions’ as a token of our heartfelt appreciation! Click here to learn more →

This Memorial Day, we honor those who gave all for our freedom. Take 20% off sitewide through May 29 with code MEMORIAL26 at checkout

CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 1 with code CYBER25

CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 2 with code CYBER24