Livanta Memo Highlight of Healthcare News Week

Dr. Ronald HirschAugust 28, 2023

The news cycle never seems to rest. First, a bill has been introduced in Congress to once again try to get observation days to count for the three-day stay requirement for Part A skilled nursing facility (SNF) coverage by Medicare.


Similar bills have been proposed for over 10 years and never get anywhere, so I have little faith that this one will be different. In addition, it makes no sense to limit it to counting observation days. Many Medicare beneficiaries would benefit from SNF care without any hospital stay.


We simply need Congress to realize that medical care in 2023 is not the same as in 1965, and the whole three-day inpatient stay requirement needs to go away.


I also have an update on the Livanta memo about short inpatient stays that I have been discussing for the last two weeks. I was looking through my files and noted that in March 2023, Livanta released a report on their short-stay inpatient audits that they had performed up to that time. And to my amazement, they reported that they had denied 11 short inpatient stays with the diagnosis of melena and 11 with a diagnosis of gastrointestinal hemorrhage. That’s the exact circumstances of one of the case examples in their memo.

Author Bio: Dr. Ronald Hirsch is Vice President of the Regulations and Education Group at R1 RCM Inc. Dr. Hirsch was a general internist and HIV specialist and practiced at Signature Medical Associates, a multispecialty practice located in Elgin, IL. He was Medical Director of Case Management at Sherman Hospital in Elgin, IL from 2006 to 2012, where he was Chairman of the Medical Records Committee from 1995 to 2012, and also served on the Medical Executive Committee. Dr. Hirsch is certified in Health Care Quality and Management by the American Board of Quality Assurance and Utilization Review Physicians, certified in Revenue Integrity by the National Association of Healthcare Revenue Integrity, and on the Advisory Board of the American College of Physician Advisors. He is on the editorial board of He is the co-author of The Hospital Guide to Contemporary Utilization Review, with the third edition published in 2021.

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