CMSA Today - Issue 5, 2016 - 25

Discharge Planning CMS Proposes Major Changes in Discharge Planning for Hospitals BY ELIZABETH E. HOGUE, ESQ O n Nov. 3, 2015, the Centers for Medicare & Medicaid Services (CMS) published proposed regulations governing discharge planning by hospitals in the Federal Register. If finalized, these proposed regulations will require hospitals to devote considerably more time and resources to discharge planning activities. Comments to these proposed regulations are due sixty days from the date of publication in the Federal Register. In addition to the requirements described in Parts 1, 2 and 3 of this series (published in Issue 1, 2016 of CMSA Todayâ„¢), if proposed regulations are finalized as drafted, hospitals will also be required to engage in the activities described below. For patients who are discharged to home and referred for home health agency (HHA) services or transferred to a skilled nursing facility (SNF), inpatient rehab facility (IRF) or long-term care hospital (LTCH) additional requirements must be met as follows: PART 4 Hospitals must include a list of HHAs, SNFs, IRFs and LTCHs in patients' discharge plans that: * Are available to discharged patients. * Participate in the Medicare Program. * HHAs that serve the geographic area in which the patient resides and SNFs, IRFs and LTCHs that are located in geographic areas requested by patients. Lists must be presented to patients for whom home health care, SNF, IRF or LTCH services are indicated and appropriate as determined by discharge planning evaluations. Hospitals must make patients enrolled in managed care organizations (MCOs) aware of the need to verify with their MCOs which providers are in network. If hospitals have such information, it must be shared with patients. Hospitals must document in patients' medical records that lists were presented to patients or patients' representatives. As part of the discharge planning process, hospitals must inform patients or patients' representatives of their freedom to choose among participating Medicare providers of post-discharge services and must respect patients' or their representatives' goals of care and treatment preferences, along with any other preferences they express. Hospitals may not specify or otherwise limit the qualified providers or suppliers that are available to patients. Discharge plans must also identify HHAs or SNFs to which patients are referred in which hospitals have disclosable financial interests or vice versa. Disclosable financial interests are determined consistent with 42 CFR 420, Subpart C. The above proposed regulations make it clear that hospitals will be required to present lists of IRFs and LTCHs in addition to HHAs and SNFs, if they are not already doing so. PART 5 If proposed regulations are finalized as drafted, CAHs will be required to meet the specific requirements regarding discharge planning described below. CAHs will be required to develop and implement effective discharge planning processes that focus on preparing patients to participate in post-discharge care, planning for post-discharge care that is consistent with patients' goals for care and treatment preferences, effective transition of patients from CAHs to post-discharge care and reduction of factors leading to preventable readmissions to CAHs or hospitals. According to the proposed regulations, policies and procedures governing discharge planning must be: * Developed with input from CAHs' professional healthcare staff and nursing leadership as well as other relevant departments. * Reviewed and approved by the governing body or responsible individual. * Reduced to writing. CAHs' discharge planning processes must also ensure that discharge goals, preferences and needs of individual patients are identified and result in development of discharge plans for each patient using the following processes: Coordination of evaluations of discharge needs and development of discharge plans by registered nurses, social workers or other personnel qualified in accordance with CAHs' discharge planning policies. Identification of anticipated goals, preferences and discharge needs for patients' within 24 hours after admission or registration. Completion of discharge planning processes prior to discharge home or transfer to another facility without delays in discharges or transfers. Identification of discharge needs and completion of discharge planning processes for patients who stay less than 24 hours. Regular re-evaluation of patients to identify changes that require modification of discharge plans and updates of discharge plans to reflect needed changes. Involvement of practitioners responsible for the care of patients in ongoing processes of establishing patients' goals of care and treatment preferences that inform discharge plans. Identification of caregiver/support persons and community-based care availability and patients' or caregivers' support persons capabilities to perform required care; including self-care, care from support person(s), follow-up care from community based providers, care from post-acute facilities or, in the case of patients admitted from long-term care or other residential facilities, care in that setting, as part of identification of discharge needs. Consideration admitting diagnoses or reason for registration, admitting diagnoses or reason for registration, relevant co-morbidities and past medical and surgical history, anticipated ongoing care needs post-discharge, Issue 5 * 2016 * DIGITAL CMSA TODAY 25

Table of Contents for the Digital Edition of CMSA Today - Issue 5, 2016

President's Letter: Leading Through Change
Immediate Past President's Letter: Risks, Challenges and Progress
Association News
CMSA Corporate Partners
Normalizing End-of-Life Care with Rich Conversations
Personal Feelings/Professional Face: The Hidden Grief of the Helping Professional
INDEX OF ADVERTISERS
CMSA Today - Issue 5, 2016 - cover1
CMSA Today - Issue 5, 2016 - cover2
CMSA Today - Issue 5, 2016 - 3
CMSA Today - Issue 5, 2016 - 4
CMSA Today - Issue 5, 2016 - 5
CMSA Today - Issue 5, 2016 - President's Letter: Leading Through Change
CMSA Today - Issue 5, 2016 - 7
CMSA Today - Issue 5, 2016 - 8
CMSA Today - Issue 5, 2016 - Immediate Past President's Letter: Risks, Challenges and Progress
CMSA Today - Issue 5, 2016 - 10
CMSA Today - Issue 5, 2016 - 11
CMSA Today - Issue 5, 2016 - Association News
CMSA Today - Issue 5, 2016 - 13
CMSA Today - Issue 5, 2016 - CMSA Corporate Partners
CMSA Today - Issue 5, 2016 - 15
CMSA Today - Issue 5, 2016 - Normalizing End-of-Life Care with Rich Conversations
CMSA Today - Issue 5, 2016 - 17
CMSA Today - Issue 5, 2016 - 18
CMSA Today - Issue 5, 2016 - 19
CMSA Today - Issue 5, 2016 - 20
CMSA Today - Issue 5, 2016 - 21
CMSA Today - Issue 5, 2016 - Personal Feelings/Professional Face: The Hidden Grief of the Helping Professional
CMSA Today - Issue 5, 2016 - 23
CMSA Today - Issue 5, 2016 - 24
CMSA Today - Issue 5, 2016 - 25
CMSA Today - Issue 5, 2016 - 26
CMSA Today - Issue 5, 2016 - INDEX OF ADVERTISERS
CMSA Today - Issue 5, 2016 - 28
CMSA Today - Issue 5, 2016 - cover3
CMSA Today - Issue 5, 2016 - cover4
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