CMSA Today - Issue 1, 2016 - (Page 14)
BY ELIZABETH E. HOGUE, ESQ
n November 3, 2015, the Centers for Medicare
and 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 60 days from
the date of publication in the Federal Register.
Proposed changes in Conditions of
Participation (CoPs) for hospitals generally
* Development and implementation of an
effective discharge planning process that
focuses on patients' goals and preferences,
and prepares patients and their caregivers/
support person(s) to be active partners in
* Planning for care that is consistent with
patients' goals for care and treatment
* Effective transition of patients from hospitals to post-discharge care.
* Reduction of factors leading to preventable
Specifically, policies and procedures of
hospitals governing discharge planning
activities must be:
* Developed with input from hospitals' medical staff, nursing leadership, and other relevant departments.
* Reviewed and approved by governing bodies of hospitals.
* Specified in writing.
The proposed regulations require the
discharge planning process to be applied to:
* All inpatients.
* Outpatients receiving observation services.
* Outpatients undergoing surgery or other
same-day procedures for which anesthesia
or moderate sedation is used.
* Emergency department patients identified in accordance with hospitals' discharge
planning policies and procedures by emergency department practitioners responsible for the care of patients who need a
* Any other category of outpatients as recommended by the medical staff and specified
in hospitals' discharge planning policies
and procedures approved by hospitals'
This change in application of discharge
planning activities alone is very significant
in terms of the resources and skills that
will be needed to meet new requirements.
Registered nurses, social workers, or other
Issue 1 * 2016 * DIGITAL
qualified personnel according to hospitals'
discharge planning policies must coordinate
an evaluation of patients' discharge needs
and development of discharge plans.
If finalized, hospitals will be required to
identify the anticipated needs of patients
following discharge within 24 hours after
admission or registration. The discharge
planning process must be completed prior
to discharge home or transfer to another
facility and without unduly delaying patients'
discharge or transfer.
If patients' stay is less than 24 hours,
discharge needs for each patient must still
be identified and the discharge planning
process completed prior to discharge
home or transfer to another facility without
unnecessarily delaying patients' discharge
As the above indicates, these proposed
regulations include major changes for
discharge planners/case managers. Now
is the time to review these proposed
regulations and submit comments, if needed.
Table of Contents for the Digital Edition of CMSA Today - Issue 1, 2016
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Discharge Planning Regulations
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CMSA Today - Issue 1, 2016