Inpatient and outpatient healthcare providers: This article will help you understand the forthcoming conditions of participation for discharge planning requirements from CMS

As you may be aware, CMS announced a new Final Rule on discharge planning in October 2015. The burdens of the rule were so significant and the uproar so great, CMS put a hold on implementation for further review. Without any additional notification, CMS announced on September 30, 2019 that the final rule was in effect – with a 60-day implementation requirement!

This is important for two reasons:

1. Final Rules are Conditions of Participation, meaning, we must be compliant with all regulatory rules in order to maintain our CMS status.

2. Certain aspects of the Final Rule are significant and will change work flows and processes across many service lines including nursing, medicine, admissions, case management, and our primary care providers.

“The Centers for Medicare & Medicaid Services (CMS) today issued a final rule that empowers patients preparing to move from acute care into post-acute care (PAC), a process called “discharge planning.” Today’s rule puts patients in the driver’s seat of their care transitions and improves quality by requiring hospitals to provide patients access to information about PAC provider choices, including performance on important quality measures and resource-use measures – including measures related to the number of pressure ulcers in a given facility, the proportion of falls that lead to injury, and the number of readmissions back to the hospital.” — CMS News Release, Sep. 26, 2019, Seema Verma, Administrator

Work is currently in progress here at Valley by the Inpatient Care Coordination and Transition (IPCCT) committee to address new requirements with multiple sub-groups created to tackle specific areas. We will not be fully compliant by the end of November; however, we will be able to demonstrate awareness of the rules and progress in the work. Because this is a work in progress, the intent of this article is to inform readers of impending changes.

Highlighted areas indicate brand new regulation:

1. The patient has the right to have a family member or representative of his or her choice and his or her own physician notified promptly of his or her admission to the hospital.
2. The patient has the right to participate in the development and implementation of his or her plan of care. The patient’s short- and long-termgoals of care, health objectives and treatment preferences must be identified, addressed and documented; and reviewed regularly.
3. Hospital’s care team must assist patients, their families, or the patient’s representative in selecting a PAC provider. Including documentation patient/caregiver participated in post-discharge options and needs assessment. Documentation in the medical record must include the PAC data on quality measures and resource use measures is relevant and applicable to the patient’s goals of care and treatment preferences and were shared with the patient and used to assist the patient during the discharge planning process.
4. Require discharge planning to include an evaluation of a patient’s likely need for appropriate post-hospital services, including, but not limited to, hospice care services, post-hospital extended care services, home health services, and non-health care services and community based care providers, and that the evaluation must also include a determination of the availability of, and the patient’s access to, those non-health care services as part of the patient’s discharge planning evaluation. We therefore urge hospitals to develop collaborative partnerships with these community-based care organizations in their respective areas to improve transitions of care that might support better patient outcomes.
5. Hospitals must discharge the patient, and transfer or refer the patient where applicable, along with all necessary medical information pertaining to the patient’s current course of illness and treatment, post-discharge goals of care, and treatment preferences, at the time of discharge, to the practitioners responsible for the patient’s follow up or ancillary care.
6. The patient has the right to access their medical records, including current medical records, upon an oral or written request, in the form and format requested by the individual, if it is readily producible in such form and format (including in an electronic form or format when such medical records are maintained electronically); or, if not, in a readable hard copy form or such other form and format as agreed to by the facility and the individual, and within a reasonable time frame. The hospital must not frustrate the legitimate efforts of individuals to gain access to their own medical records and must actively seek to meet these requests as quickly as its record keeping system permits.