New Conditions of Participation for Hospital Discharge Planning: Patients’ Right to Freedom of Choice Sitecare Support December 27, 2019 The Centers for Medicare and Medicaid Services (CMS) published a final rule on September 30, 2019, that requires hospitals to make substantial changes in discharge planning. 2019 - An Update on Discharge Planning Rules and Regulations for 2019. According to CMS, discharge planners/case managers must put forth their “best effort” to answer patients’ questions about the data. CMS says that hospital discharge planners/case managers are not expected to provide patients and their caregivers with detailed and complex analyses of quality and resource use data that may confuse patients and their caregivers. Stay tuned! The Centers for Medicare and Medicaid Services (CMS) published a final rule on September 30, 2019, that requires hospitals to make substantial changes in discharge planning. (c) Standard: Requirements related to post-acute care services. EDITOR’S NOTE: The following are edited remarks by Mary Beth Pace, the author who was a panelist on Monitor Mondays Nov. 25, reporting on how Trinity Health is preparing to implement the final rule on discharge planning conditions of participation from the Centers for Medicare & Medicaid Services (CMS). The Centers for Medicare & Medicaid Services (CMS) has finalized changes to the discharge planning conditions of participation (CoPs) for hospitals (including long-term care hospitals (LTCHs) and inpatient rehabilitation hospitals (IRFs)), critical access hospitals (CAHs), and home health agencies (HHAs). In response to concerns about hospital discharge planners/case managers that may attempt to “steer” patients to particular post-acute providers, CMS says that they must present objective data on quality and resource measures specifically applicable to patients’ goals of care and treatment preferences, “taking care to include data on all available PAC providers and allowing patients and/or their caregivers the freedom to select a PAC provider of their choice.”. (7) The hospital must assess its discharge planning process on a … New discharge planning requirements, as mandated by the IMPACT act for hospitals, HHAs, and CAHs, that requires facilities to assist patients, their families, or the patient’s representative in selecting a post-acute care (PAC) services provider or supplier by using and sharing PAC data on quality measures and resource use measures. (4) Upon the request of a patient's physician, the hospital must arrange for the development and initial implementation of a discharge plan for the patient. Click here for more information. The hospital's discharge planning process must identify, at an early stage of hospitalization, those patients who are likely to suffer adverse health consequences upon discharge in the absence of adequate discharge planning and must provide a discharge planning evaluation for those patients so identified as well as for other patients upon the request of the patient, patient's representative, or patient's physician. In 2019, CMS provided the elements of the proposed rules that would be adopted in November 2019. We use Google Analytics to collect information about visitor behaviour on our website. The discharge plan must be updated, as needed, to reflect these changes. All rights reserved. You can find out more about Google’s position on privacy as regards its analytics service at http://www.google.com/intl/en_uk/analytics/privacyoverview.html, New Conditions of Participation for Hospital Discharge Planning: Patients’ Right to Freedom of Choice, Common Misunderstandings About Medicare/Medicaid Fraud and Abuse, Discharge Planners Must Stop Accepting Kickbacks and Managers Must Monitor Receipt, Recent Fraud Enforcement Action: Lessons for Providers. A Reason to Celebrate Case Management Week Early Even though Case Management Week is not for two weeks (October 13 – 19, 2019), the release of the Discharge Planning Conditions of Participation (CoP) Final Rule is a reason for an early celebration as evidenced by … The Centers for Medicare & Medicaid Services (CMS) released a final rule Thursday that makes changes to discharge planning requirements for home health providers. New Conditions of Participation for Hospital Discharge Planning: Patients’ Right to Freedom of Choice Published on October 14, 2019 October 14, 2019 • 17 Likes • 2 Comments your name or address) so this information cannot be used to identify who you are. Camdenton, MO 65020, (866) 428-4040 toll-free The hospital must ensure that the post-acute care data on quality measures and data on resource use measures is relevant and applicable to the patient's goals of care and treatment preferences. The discharge planning process and the discharge plan must be consistent with the patient's goals for care and his or her treatment preferences, ensure an effective transition of the patient from hospital to post-discharge care, and reduce the factors leading to preventable hospital readmissions. Revises the discharge planning requirements that hospitals (including long-term care hospitals, Critical Access Hospitals (CAHs) psychiatric hospitals, children’s hospitals, and cancer hospitals), inpatient rehabilitation facilities, and home health agencies must meet to participate in Medicare and Medicaid programs. § 482.43 Condition of participation: Discharge planning. The hospital must discharge the patient, and also 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 appropriate post-acute care service providers and suppliers, facilities, agencies, and other outpatient service providers and practitioners responsible for the patient's follow-up or ancillary care. The Context for Discharge Planning to a PAC Facility 2 Relevant Regulations 2 Conditions of Participation for Medicare 2 New York Codes, Rules and Regulations, Title 10 3 Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014 3 The Hospital Perspective on Discharge Planning for PAC 4 Patient Assessment for Discharge 4 For those patients discharged home and referred for HHA services, or for those patients transferred to a SNF for post-hospital extended care services, or transferred to an IRF or LTCH for specialized hospital services, the following requirements apply, in addition to those set out at paragraphs (a) and (b) of this section: (1) The hospital must include in the discharge plan a list of HHAs, SNFs, IRFs, or LTCHs that are available to the patient, that are participating in the Medicare program, and that serve the geographic area (as defined by the HHA) in which the patient resides, or in the case of a SNF, IRF, or LTCH, in the geographic area requested by the patient. (7) The hospital must assess its discharge planning process on a regular basis. The Centers for Medicare & Medicaid Services (CMS) proposed major changes to the discharge planning conditions of participation in 2015. PO Box 237 (866) 463-7550 fax 2019 Articles Archive. (b) Standard: Discharge of the patient and provision and transmission of the patient's necessary medical information. CMS also states that the IMPACT Act requires hospitals to take into account quality, resource use and other measures in the discharge planning process. Case management IS care coordination Published: Aug 13, 2019 CMS Issues New Conditions of Participation for Discharge Planning for Hospitals and Home Health Agencies Published: Oct 01, 2019. CENTERS FOR MEDICARE & MEDICAID SERVICES, DEPARTMENT OF HEALTH AND HUMAN SERVICES, Subchapter G. STANDARDS AND CERTIFICATION, Part 482. The provisions of this part serve as the basis for survey activities for the purpose of determining whether an agency meets the requirements for participation in the Medicare program. Standard: Requirements related to post-acute care services. If the hospital has information on which practitioners, providers or certified supplies are in the network of the patient's managed care organization, it must share this with the patient or the patient's representative. New Discharge Planning Conditions of Participation (CoPs) require hospitals to assist patients, their families, or their caregivers/support persons in selecting a Post-Acute Care (PAC) provider by using and sharing data that includes, but is not limited to, HHA, SNF, IRF, or LTCH data on quality measures and data on resource use measures. The hospital must have an effective discharge planning process that focuses on the patient's goals and treatment preferences and includes the patient and his or her caregivers/support person (s) as active partners in the discharge planning for post-discharge … Final rule becomes effective Friday, Nov. 29, 2019. After granting themselves a one-year reprieve, they released the final rule in late September. This site uses functional cookies and external scripts to improve your experience. CMS says that providers will have to document all interactions regarding freedom of choice in patients’ medical records. CMS believes the rule, which implements statutory requirements under the … The hospital must have an effective discharge planning process that focuses on the patient's goals and treatment preferences and includes the patient and his or her caregivers/support person(s) as active partners in the discharge planning for post-discharge care. (a) Standard: Discharge planning process. (a) Standard: Discharge planning. The final rule was released on Sept. 25, 2019. Further information mandated by the IMPACT Act will be available in forthcoming regulations. The extension runs through November 3, 2019. HHAs must request to be listed by the hospital as available. CMS took the unusual step on October 30 of announcing a year’s time extension to publish the final rule. Discharge Planning: Compliance with the New CMS Conditions of Participation. The assessment must include ongoing, periodic review of a representative sample of discharge plans, including those patients who were readmitted within 30 days of a previous admission, to ensure that the plans are responsive to patient post-discharge needs. § 482.43 - Condition of participation: Discharge planning. (iii) The hospital must document in the patient's medical record that the list was presented to the patient or to the patient's representative. § 482.43 Condition of participation: Discharge planning. ... (CMS) discharge planning standards that became effective Nov. 29, 2019. (ii) For patients enrolled in managed care organizations, the hospital must make the patient aware of the need to verify with their managed care organization which practitioners, providers or certified suppliers are in the managed care organization's network. 484.1(b) Scope. CMS will also provide interpretive guidelines at some point after publication of the final rule. If you were expecting to implement the latest discharge planning revisions to the Medicare Conditions of Participation soon, you can breathe a little easier for now. Nonetheless, hospitals, CAHs, and HHAs will need to update or create new discharge planning processes by November 29, 2019 to comply with new conditions of participation … Standard: Discharge of the patient and provision and transmission of the patient's necessary medical information. (7) The hospital must assess its discharge planning process on a regular basis. 484.1(a)(2) Section 1861(z) of the Act, which specifies the institutional planning standards that HHAs must meet. Under the revised Conditions of Participation, hospitals and CAHs must provide expanded discharge planning to patients likely to suffer adverse health consequences upon discharge without adequate discharge planning as well as for other patients upon the request of the patient, patient’s representative, or physician. These apply to all hospitals that accept Medicare and Medicaid, and, for the first time, will apply to critical access hospitals. On September 26, 2019, the Centers for Medicare and Medicare Services (“CMS”) released the final rule on discharge planning requirements (the “Final Rule”) in an effort to empower patients to be active participants in the discharge planning process. The hospital must not specify or otherwise limit the qualified providers or suppliers that are available to the patient. prior to discharge Discharge planning •Hospice must have a discharge planning process •Process must include planning for any necessary family counseling, patient education, or other services before the patient is discharged because he or she ... 12/9/2019 16 Conditions of Participation (CoPs) Subparts C&D 31 2008 CoP Foundations This site uses functional cookies and external scripts to improve your experience. These proposed rules were to be used to update the current rules under the Conditions of Participation for Discharge Planning. This tool, adapted from the CMS Conditions of Participation (COPs), provides a checklist of discharge elements that CMS states should be provided to all Medicare and Medicaid patients. An HHA must develop and implement an effective discharge planning process. (6) The hospital's discharge planning process must require regular re-evaluation of the patient's condition to identify changes that require modification of the discharge plan. CMS says that case managers/discharge planners should also refer to www.medicare.gov for additional resources and help with regard to data presented to patients. First, CMS clarifies that CoPs for hospitals apply to acute care hospitals, long-term care hospitals (LTCHs), independent rehab facilities (IRFs), short-term acute care hospitals, rehabilitation hospitals, psychiatric hospitals, children’s hospitals and cancer hospitals. Items are to be assessed by a combination of observation, interviews with hospital staff, review of the hospital’s discharge planning program documentation including policies and procedures, and review of medical records. Section 482.43. This Analytics data is collected via a JavaScript tag in the pages of our site and is not tied to personally identifiable information.We therefore do not collect or store your personal information (e.g. 42 CFR 484.2 Definitions. Financial interests that are disclosable under Medicare are determined in accordance with the provisions of part 420, subpart C, of this chapter. Condition of participation: Discharge planning. (3) The discharge planning evaluation must be included in the patient's medical record for use in establishing an appropriate discharge plan and the results of the evaluation must be discussed with the patient (or the patient's representative). §482.42 Condition of Participation: Infection Prevention and Control and Antibiotic Stewardship Programs §482.43 Condition of Participation: Discharge Planning §482.45 Condition of Participation: Organ, Tissue and Eye Procurement Please join us! (2) A discharge planning evaluation must 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 must also include a determination of the availability of the appropriate services as well as of the patient's access to those services. (3) The discharge plan must identify any HHA or SNF to which the patient is referred in which the hospital has a disclosable financial interest, as specified by the Secretary, and any HHA or SNF that has a disclosable financial interest in a hospital under Medicare. We will provide more information soon. The discharge plan must be updated, as needed, to reflect these changes. Electronic Code of Federal Regulations (e-CFR), Chapter IV. CMS’ Revisions to Hospitals’ Discharge Planning Requirements The proposed rule set forth six standards for discharge planning in the Conditions of Participation. We will present a teleconference on October 23, 2019, from 1:00 to 2:30 p.m. EST to review the changes to the Conditions of Participation (CoPs) in depth. A final rule revises and implements discharge planning requirements that hospitals, critical access hospitals (CAHs), and home health agencies (HHAs) must meet as a condition of participation (CoP) in the Medicare and Medicaid programs. — CMS News Release, Sep. 26, 2019. (i) This list must only be presented to patients for whom home health care post-hospital extended care services, SNF, IRF, or LTCH services are indicated and appropriate as determined by the discharge planning evaluation. (8) The hospital must assist patients, their families, or the patient's representative in selecting a post-acute care provider by using and sharing data that includes, but is not limited to, HHA, SNF, IRF, or LTCH data on quality measures and data on resource use measures. (6) The hospital's discharge planning process must require regular re-evaluation of the patient's condition to identify changes that require modification of the discharge plan. (6) The hospital’s discharge planning process must require regular re-evaluation of the patient’s condition to identify changes that require modification of the discharge plan. CONDITIONS OF PARTICIPATION FOR HOSPITALS. This tool can be used to update existing processes and identify whether … In 2015, CMS introduced proposed rules for discharge planning. Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on. In the meanwhile, many hospital discharge planners/case managers and post-acute providers who receive referrals from hospitals are especially interested in any changes regarding patients’ right to freedom of choice. NOTE: These settings will only apply to the browser and device you are currently using. On September 30, 2019, the Centers for Medicare & Medicaid Services (“CMS”) published a final rule regarding discharge planning (“Final Rule”) addressing care transitions and patient access to medical information. Your choices will not impact your visit. In other words, no “homemade data!”. The current discharge planning requirements under the Conditions of Participation for Discharge Planning The new CMS changes related to transitional and discharge planning and how they will impact your practice New Conditions of Participation for Discharge Planning for Hospitals: Access to Medical Records Sitecare Support January 13, 2020 The Centers for Medicare and Medicaid Services (CMS) published a final rule on September 30, 2019, that requires hospitals to make substantial changes to discharge planning. CMS then clarifies that discharge planners/case managers cannot make decisions on post-acute services on behalf of patients and their caregivers. (5) Any discharge planning evaluation or discharge plan required under this paragraph must be developed by, or under the supervision of, a registered nurse, social worker, or other appropriately qualified personnel. The final rule (Revisions to Discharge Planning Requirements [CMS-3317-F]) revises the discharge planning requirements that hospitals (including long-term care hospitals, critical access hospitals [CAHs] psychiatric hospitals, children’s hospitals, and cancer hospitals), inpatient rehabilitation facilities, and home health agencies must meet to participate in Medicare and Medicaid programs. Which cookies and scripts are used and how they impact your visit is specified on the left. Discharge Planning in Religious Nonmedical Health Care Institutions (RNHCIs) We have revised the requirements at 42 CFR 403.736 (a) and (b) pertaining to a discharge plan. families during the discharge planning process in order to encourage patients and caregivers to become active participants in their transition to PAC or other settings. Specifically, CMS says that hospitals’ discharge planners/case managers must use IRF Compare, Home Health Compare, Nursing Home Compare and Long-Term Care Compare to assist patients and their caregivers to make decisions about post-acute providers. Hospitals must focus instead on person-centered care to ensure the active participation of patients and their caregivers in decisions about post-acute care. (1) Any discharge planning evaluation must be made on a timely basis to ensure that appropriate arrangements for post-hospital care will be made before discharge and to avoid unnecessary delays in discharge. Planning Condition of Participation. The hospital must have an effective discharge planning process that focuses on the patient 's goals and treatment preferences and includes the patient and his or her caregivers/support person (s) as active partners in the discharge planning for post-discharge … Care Coordination Across the Continuum Published: Sep 03, 2019. The discharge plan must be updated, as needed, to reflect these changes. The final rule is effective sixty days from publication, so it becomes effective on November 29, 2019. It also forbids hospitals from “steering” patients to preferred providers or limiting patient choice in any way. 5 Star Consultants, LLC Case managers/discharge planners are also not expected to attempt to provide patients with data that does not exist. ©2019 Elizabeth E. Hogue, Esq. CMS moves to empower patients to be more active participants in the discharge planning process. New Conditions of Participation for Discharge Planning for Hospitals: Access to Medical Records Published on October 21, 2019 October 21, 2019 • 19 Likes • 0 Comments The final rule emphasizes that the discharge planning process should involve the patient as an active participant and respect the patient’s goals of care and treatment preferences. You may change your settings at any time. 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