Stay ahead of developments in federal and state health care law, regulation and transactions with timely, expert news and analysis.
By Michael D. Williamson
Jan. 6 — Parts of the CMS's discharge planning proposal for Medicare and Medicaid beneficiaries may be expensive and difficult to implement, according to the nation's largest hospital industry group.
“For example, we expect the rule, as proposed, would require hospitals to add staff, especially during the weekend and after-hours; train or retrain new and existing staff; change practitioner and administrative workflow and procedures; and alter electronic health record (EHR) systems to align with the proposed standards,” the American Hospital Association (AHA) told the Centers for Medicare & Medicaid Services in a Jan. 4 letter.
Other provider groups expressed support for the proposal. The American Health Care Association commended the rule's requirement that hospitals discuss the patient's post-acute care goals and treatment preferences with the patient, the patient's family or their caregiver/support people and subsequently document these goals and references in the medical record. The nursing home industry group made its comments in a Jan. 4 letter.
Under the rule, hospitals and other facilities would evaluate patients for their discharge needs and develop specific written discharge plans for them. At present, hospitals have some discretion and not every patient receives specific, written instructions.
The rule would revise discharge planning requirements that hospitals, including long-term care hospitals and inpatient rehabilitation facilities, home health agencies and critical access hospitals, must meet to participate in the Medicare and Medicaid programs. In addition, the rule would enact the discharge planning requirements of the Improving Medicare Post-Acute Care Transformation (IMPACT) Act, which President Barack Obama signed in October 2014 (194 HCDR, 10/7/14).
The CMS released the discharge planning requirements proposed rule in late October 2015 and it was published in the Nov. 3 Federal Register (80 Fed. Reg. 68,126) (210 HCDR 210, 10/30/15). Comments (CMS-3317-P) were due Jan. 4.
In its Jan. 4 comments, the National Association for Home Care & Hospice (NAHC) recommended that the CMS “fully evaluate the proposed standards with the goal of streamlining paperwork issues.”
The NAHC, which represents the home-care and hospice industries, also told the agency it should take all steps necessary to clarify the discharge requirements so providers and the CMS have a mutual understanding of what it takes to be compliant, because the current proposal “contains vague standards.” Clarifying requirements could reduce conflict between the CMS and providers, the group said.
Similarly, a trade group for safety-net hospitals, America's Essential Hospitals (AEH), urged the agency to develop discharge planing requirements that won't place additional administrative burdens on providers.
Essential, or safety-net hospitals “already operate, on average, with a negative margin,” and the proposal's requirements to improve care coordination among providers could prove challenging, AEH said in a Dec. 22 letter. “Our members face challenges in finding the resources necessary for improvements, such as upgrading technology, redesigning processes, and enhancing personnel.”
The AHA, NAHC and AEH each noted in their comments that they generally support the discharging proposal.
To contact the reporter on this story: Michael D. Williamson in Washington at firstname.lastname@example.org
To contact the editor responsible for this story: Brian Broderick at email@example.com
All Bloomberg BNA treatises are available on standing order, which ensures you will always receive the most current edition of the book or supplement of the title you have ordered from Bloomberg BNA’s book division. As soon as a new supplement or edition is published (usually annually) for a title you’ve previously purchased and requested to be placed on standing order, we’ll ship it to you to review for 30 days without any obligation. During this period, you can either (a) honor the invoice and receive a 5% discount (in addition to any other discounts you may qualify for) off the then-current price of the update, plus shipping and handling or (b) return the book(s), in which case, your invoice will be cancelled upon receipt of the book(s). Call us for a prepaid UPS label for your return. It’s as simple and easy as that. Most importantly, standing orders mean you will never have to worry about the timeliness of the information you’re relying on. And, you may discontinue standing orders at any time by contacting us at 1.800.960.1220 or by sending an email to firstname.lastname@example.org.
Put me on standing order at a 5% discount off list price of all future updates, in addition to any other discounts I may quality for. (Returnable within 30 days.)
Notify me when updates are available (No standing order will be created).
This Bloomberg BNA report is available on standing order, which ensures you will all receive the latest edition. This report is updated annually and we will send you the latest edition once it has been published. By signing up for standing order you will never have to worry about the timeliness of the information you need. And, you may discontinue standing orders at any time by contacting us at 1.800.372.1033, option 5, or by sending us an email to email@example.com.
Put me on standing order
Notify me when new releases are available (no standing order will be created)