On October 29, 2015, the Centers for Medicare & Medicaid Services (CMS) proposed to revise the discharge planning requirements for hospitals, long-term care hospitals, critical access hospitals and home health agencies under the conditions of Medicare participation for each provider type. In comparison to current practice, the proposed rule would expand the number and types of patients to whom written discharge plans are issued. CMS believes that the proposed changes to the discharge planning rules will result in fewer avoidable hospital readmissions and patient complications post-discharge by having a more patient-focused discharge planning process.
Notable Proposed Changes
Under the proposed rule, hospitals, long-term care hospitals and critical access hospitals must develop a written discharge plan for all inpatients, outpatients receiving observation services, outpatients undergoing surgery or other same day procedures for which anesthesia or moderate sedation are used, emergency department patients identified by a practitioner responsible for the care of the patient, and any other category of outpatients specified in the hospital’s discharge planning policies and procedures. The proposed rule also clarifies the actions providers must take during the discharge planning process, sets the minimum requirements for discharge instructions, standardizes the necessary medical information providers must send to a receiving facility, and implements the discharge planning requirements of the Improving Medicare Post-Acute Care Transformation Act of 2014. Specific notable requirements of the proposed discharge planning rules include the following:
- The development of discharge plans that are patient-focused, which take into consideration the patient’s goals and preferences for treatment, and prepare patients and their caregivers to actively participate in discharge care.
- The identification of anticipated discharge needs for applicable patients within 24 hours after admission or registration and completion of the discharge planning process before a patient is discharged home or transferred to another facility.
- The dissemination of written discharge instructions at the time of discharge to patients and caregivers when a patient is discharged to home, the community, hospice services or other outpatient health care services. These discharge instructions must include post-hospital care instructions, information on warning signs and symptoms indicating the need for immediate medical care, required prescriptions and over-the-counter medications, reconciliation of a patient’s medications and information regarding follow-up care, appointments, tests and provider contact information.
- The provision of specific necessary medical information, including a copy of a patient’s discharge instructions and discharge summary, to a receiving facility at the time of transfer to the facility.
- The establishment of a post-discharge follow-up process for patients being “discharged to home” and the dissemination of certain information to practitioners responsible for follow-up care, if known. This information includes a copy of discharge instructions and a discharge summary within 48 hours of discharge, pending test results within 24 hours of availability and other necessary medical information.
- The assistance of patients and their caregivers in selecting a post-acute care provider by using and sharing data on quality measures and resource use measures.
*Wendy Wright is admitted only in North Carolina. Her practice is supervised by principals of the firm admitted in the District of Columbia.