During the COVID-19 public health emergency, the Centers for Medicare and Medicaid Services waived the annual average 96-hour patient length-of-stay requirement for critical access hospitals. CMS is resuming the standard practice to evaluate the requirement starting with hospitals’ first full cost-reporting period after May 11, that does not include any of the months covered under the public health emergency blanket waiver.
CMS issued memorandum QSO-23-17-CAH providing guidance on the 96-hour patient length of stay standard:
• Medicare-certified CAHs are required to meet the annual 96-hour average patient length of stay standard for acute inpatient care under the CAH Conditions of Participation (CoPs) at 42 CFR §485.620(b).
• During the COVID-19 Public Health Emergency (PHE), CMS waived the requirement that CAHs limit the annual average patient length of stay to 96 hours. This waiver was in effect from March 1, 2020, through the end of the PHE on May 11, 2023.
• The purpose of this memo is to provide guidance to the SAs of a one-time change to the CAH 96-hour patient length of stay calculation to account for the time period of the PHE.
