CMS’ Proposed Discharge Rule Puts the Patient and Their Caregivers at the Center of Care Delivery

The Centers for Medicare & Medicaid Services (CMS) is proposing to revise the discharge planning requirements for hospitals including long-term care hospitals, inpatient rehabilitation facilities, critical access hospitals and home health agencies. This is a welcome step as patients’ post-discharge needs are multi-factorial necessitating a significant level of ongoing planning and coordination among health care practitioners, facilities caring for a patient currently and those who will provide post-acute care. The revised discharge planning requirements will streamline the process by bringing them into closer alignment with current practice.

For example, Mr.Scholl is being discharged home, but requires physical therapy support. In the current situation, the hospital discharge planner is called to arrange for home health services. However, things will not be that simple with the proposed changes because CMS has very specific rules addressing the post-discharge arrangement of home health and skilled nursing facility services.

According to the proposed rule, hospitals and CAHs would be required to create discharge plans for all inpatients as well as some outpatients. This includes same-day patients receiving anesthesia or moderate sedation, emergency department patients whom a practitioner identifies as needing a discharge plan, observation patients, and others. The discharge planning process need to consider the patient’s preferences, as well as certain quality, resource use and other measures, as required by the 2014 Improving Medicare Post-Acute Care Transformation Act (IMPACT).

The AHA has generally supported the proposed rule; however, the association stated, the final rule should allow hospitals to “tailor the discharge planning activities to the needs of each patient,” The AHA expressed concerns on certain points, and urged CMS to make several key changes in the final CMS rule that would lessen the burden on hospitals and CAHs.

According to AHA’s key concerns, CMS should:

  • Change the scope of the proposed requirements so that either discharge plans or discharge instructions can be provided in certain instances to better align discharge planning efforts with the needs of each patient.
  • Alter a proposal that would require discharge planning to begin within 24 hours in all cases.
  • Provide flexibility to address the lack of community resources in some areas.
  • Revisit its cost estimates to reflect the true impact of increasing the discharge planning requirements.
  • Establish an effective date that is two years from the date of the final rule.

To keep you on track, AudioEducator will host an audio session on the CMS Proposed Changes to the Discharge Planning Standards and the IMPACT Act, where our expert speaker Sue Dill Calloway, RN, MSN, JD, will shed light on how to comply with the impact of the CMS proposed changes. Join her to learn about the five things that must be included in discharge instructions, and get some expert insights.

To read more about the proposal, and AHA’s opinion, click HERE and HERE

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