CMS Discharge Proposal Too Expensive, Hospital Group Says

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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.

Paperwork Burdens?

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.

Safety-Net Hospitals

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

To contact the editor responsible for this story: Brian Broderick at

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