Press Release

Statement on Two-Midnight Enforcement Delay Extension

Rick Pollack

Executive Vice President
American Hospital Association 

August 12, 2015


The AHA is pleased that the Centers for Medicare & Medicaid Services (CMS) has extended the partial enforcement delay of the two-midnight policy through the end of the year, which would continue to prevent Recovery Audit Contractors (RACs) from issuing inappropriate denials for medically necessary patient care. The enforcement delay had been set to expire Sept. 30. The AHA strongly urged CMS to extend this enforcement delay because CMS’s proposed changes to the two-midnight policy would not take effect until Jan. 1. 

We also appreciate that CMS provided further details related to changes in the agency’s education and enforcement strategies for patient status claims. We will continue to work with the agency as it finalizes its two-midnight policy changes and implements reforms to the flawed RAC program.   



About the AHA

The AHA is a not-for-profit association of health care provider organizations and individuals that are committed to the health improvement of their communities. The AHA is the national advocate for its members, which include nearly 5,000 hospitals, health care systems, networks, other providers of care and 43,000 individual members. Founded in 1898, the AHA provides education for health care leaders and is a source of information on health care issues and trends. For more information, visit the AHA website at

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