To ensure accurate tracking of the Two-Midnight requirement for inpatient level of care, CMS allows hospitals to use the Occurrence Span Code 72 to track outpatient care prior to inpatient admission.
Previously, the inpatient claim only allowed CMS to track inpatient time after a patient was formally admitted as an inpatient.
Using the Occurrence Span Code 72 allows providers and review contractors to identify the total number of midnights on the face of the claim (inpatient and observation).
Time receiving outpatient care in the hospital that can be reported in the Occurrence Span Code 72 includes:
- Observation services
- Treatment in the ED
- Surgical procedures
Time spent at a transferring facility counts toward the Two-Midnight rule and should also be reported with the Occurrence Span Code 72.
Note: PEPPER “one day stay” reports exclude patients whose claims include an Occurrence Span Code 72 with a total stay of ≥ 2 midnights.
