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Does an observation day count in the annual 96-hour average limit?

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Does an observation day count in the annual 96-hour average limit?

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No, the time a patient spends in an observation bed within that facility does not count in the annual 96-hour average. The use of an observation bed is not to be substituted for inpatient care. The intermediaries can and will deny payment for medically unnecessary outpatient observation.

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