Martin Health Care, Robbins, Howard--FL

Under the proposed rule, the exact timing of the admission becomes very important, since although not the only consideration, staying two midnights or such becomes a key determining factor in inpatient vs observation. Many hospitals in Florida have Emergency rooms that and hospitals that are at capacity in "season". THe result is that someone can be seen in the emergency room and admission orders signed by the physician, but may NOT leave the emergency room for many hours,, although they are being treated as an admission and the orders and intensity of service are being provided, the same as if they were moved to a "formal bed" in the hospital. In some good hospitals, it may not be possible to move that patient out of the ER for many hours. I would propose that the timing of inpatient start when: 1. AN impatient order by physician is documented AND 2. Either the patient is in an inpatient bed OR traiged into a bed in the emergency room. If timing is to be a key element in defining inpatient/vs observation, this is must in fairness to hospitals.