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Inpatient Psychiatric Certification/Recertification/Delayed Certification

Physicians are required to certify the medical necessity of inpatient services. This is required on admission and if the service is needed for an extended period of time, a recertification is necessary. When these requirements are not met during audits, payments for services are denied.

CMS issued MLN article MM9522:Clarification of Inpatient Psychiatric Facilities (IPF) Requirements for Certification, Recertification and Delayed/Lapsed Certification and Recertification to clarify certification requirements for inpatient psychiatric stays.

CR9522 addresses physician certification, recertification and delayed/lapsed certification and recertification with respect to IPF services. This CR is an update to the CMS IOM Publication 100-01, Medicare General Information, Eligibility and Entitlement Manual, Chapter 4, Physician Certification and Recertification of Services, Section 10.9.and the CMS IOM Publication 100-02, Medicare Benefit Policy Manual, Chapter 2, Inpatient Psychiatric Hospital Services, Section 30.2.1

Initial Certification

The physician is required to document that the IPF admission was medically necessary for either: (1) treatment which could reasonably be expected to improve the patient's condition, or (2) diagnostic study.


Recertification should state that the patient continues to need, on a daily basis, active treatment furnished directly by or requiring the supervision of inpatient psychiatric facility personnel.

Delayed Certification

Delayed certifications and recertifications will be honored where, for instance, there has been an oversight or lapse, and there is a legitimate reason for the delay. Denials for this reason will be technical and can be reopened. Providers are advised to submit an explanation – give legitimate reason for delay and any medical or other evidence explaining the delay. A delayed certification may be included with one or more recertifications on a single signed statement. Delayed certification may not extend past discharge.


No specific procedures or forms are required for certification, recertification and delayed certification. The format of all certifications and recertifications and the method by which they are obtained is determined by the individual facility. All the above certifications must be signed by a physician.

Inpatient Psychiatric Certification/Recertification/Delayed Certification
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