Meaningful Use Advice: Including Newborns in Inpatient Counts

Including or excluding newborn infants in generalized numerator and denominator statistics could make a difference between pass and fail in some requirements for many hospitals. The Final Rule addresses this, by generally excluding newborns from such counts. Be sure and adjust your reporting metrics based on excluding newborns! The one exception appears to be that newborns should be included in ICU counts, in denominator and where appropriate, in numerator calculations.

In excluding nursery days from the count of Medicare inpatient bed days, we are following the precedent of not counting such days for purposes of the direct medical education, indirect medical education, and disproportionate share adjustments under the Medicare IPPS. As in the case of the term “subsection (d)” hospital, we believe that, in the absence of clear direction from the statute to the contrary, the most appropriate policy is to interpret terms such as “inpatient bed-days” in the light of existing Medicare program policies and precedents.

Under our policies for the direct medical education, indirect medical education and disproportionate share adjustments, a bed must be permanently maintained for lodging inpatients in order to be included in available inpatient bed and inpatient bed day counts. We exclude the days provided to newborns (except for those in intensive care units of the hospital) because healthy new born infants are not provided with an acute level of hospital care. (This is not the case with newborns assigned to intensive care units, who are included in the counts for those units.) For these reasons, nursery days are explicitly excluded from:

The counts of Medicare inpatient hospital days and total inpatient hospital days for purposes of direct graduate medical education payments under section 413.75(b) of the regulations, where the definition of Medicare patient load reads: “inpatient days in any distinct part of the hospital are included and nursery days are excluded.”
The counts of bed days for purposes of the Medicare indirect graduate medical education adjustment under section 412.105(b): the “count of available bed days excludes bed days associated with… (5) Beds or bassinets in the healthy newborn nursery….”
The count of beds for purposes of the Medicare DSH adjustment under section412.106(a)(i) of the regulations: “The number of beds in a hospital is determined in accordance with §412.105(b).”
We note that, in addition to excluding nursery days from the numerator of the Medicare share fraction, these days are excluded for the same reasons from the count of total inpatient bed days in the denominator of the Medicare share fraction. We therefore do not believe that excluding these days would result in disadvantage to hospitals in determining their Medicare share fractions for purposes of calculating EHR incentive payments.

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