"I have heard anecdotal reports of hospitals ...

... timing the admission of the patient to avoid financial responsibility for ambulance transports between their related facilities. If a health care system is influencing the timing of the admission order because CMS says the inpatient decision is based on the timing of the order, I can see a compliance trap. If the facility decides to interfere with the professional judgment of the physician for financial reasons, I could see OIG and potentially [whistleblowers] being interested in that. Hospitals have to be careful to avoid undue interest in the timing of admission solely as it relates to financial responsibility."

— Doug Wolfberg, with Page, Wolfberg & Mirth in Mechanicsburg, Pa., told AIS's Report on Medicare Compliance.