As CMS executes Year 2 of its multi-year phase-out to eliminate the Inpatient-Only (IPO) list, hospitals face the immediate challenge of migrating 637 complex surgical codes to outpatient payment status. Delivered two months into the 2027 transition, this lecture equips facility coders, auditors, and utilization review managers with an operational survival guide. We will analyze early claim denial data, dissect the Two-Midnight rule documentation requirements necessary to justify inpatient stays, and address aggressive Medicare Advantage site-of-service audits. Attendees will leave with a practical framework to configure internal workflows and protect surgical service line revenue

Learning Objectives

· Analyze the 637 surgical codes removed from the IPO list for 2027, mapping them directly to their newly assigned Ambulatory Payment Classifications (APCs).

· Evaluate clinical documentation using the "Two-Midnight Rule" to distinguish between compliant inpatient status and outpatient placement for migrated surgeries.

· Mitigate immediate revenue risks by identifying early billing rejections and tracking variable Medicare Advantage site-of-service audit criteria.

· Formulate a clinical documentation integrity (CDI) query strategy to ensure physicians explicitly capture patient-specific comorbidities that defend the site of care