So this isn't a proposed rule for SNFs. Proposed discharge
planning requirements for SNFs are addressed in the proposed rule,
“Medicare and Medicaid Programs; Reform of Requirements for Long-Term Care
Facilities” (80 FR 42167, July 16, 2015) at https://www.federalregister.gov/articles/2015/07/16/2015-17207/medicare-and-medicaidprograms-reform-of-requirements-for-long-term-care-facilities.
But, as noted in the highlighted section below, this proposed rule
would impact SNFs because for example hospitals, critical access hospitals,
IRFs, and home health agencies would be required to share a SNF's QM and
resource use data to help patients and caregivers choose a SNF. There are a few
other issues of note for SNFs too.
Discharge Planning
Proposed Rule Focuses on Patient Preferences
Today, the Centers for Medicare & Medicaid Services (CMS)
proposed to revise the discharge planning requirements that hospitals,
including long-term care hospitals and inpatient rehabilitation facilities,
critical access hospitals, and home health agencies, must meet in order to
participate in the Medicare and Medicaid programs. The proposed changes would
modernize the discharge planning requirements by: bringing them into closer
alignment with current practice; helping to improve patient quality of care and
outcomes; and reducing avoidable complications, adverse events, and
readmissions.
The proposed rule would also implement the discharge planning
requirements of the Improving Medicare Post-Acute Care Transformation Act of
2014 (IMPACT Act), which will improve consumer transparency and beneficiary
experience during the discharge planning process. The IMPACT Act requires
hospitals, critical access hospitals, and certain post-acute care providers to
use data on both quality and resource use measures to assist patients during
the discharge planning process, while taking into account the patient's goals
of care and treatment preferences.
“CMS is proposing a simple but key change that will make it
easier for people to take charge of their own health care. If this policy is
adopted, individuals will be asked what's most important to them as they choose
the next step in their care – whether it is a nursing home or home care,”
said CMS Acting Administrator Andy Slavitt. “Policies like this put real
meaning behind the words consumer-centered health care.”
Improved Discharge Planning for Hospitals, Critical Access
Hospitals, and Home Health Agencies:
As called for in the IMPACT Act, hospitals, including inpatient
rehabilitation facilities and long-term care hospitals, critical access
hospitals, and home health agencies would be required to develop a discharge
plan based on the goals, preferences, and needs of each applicable patient .
Under the proposed rule, hospitals and critical access hospitals would be required
to develop a discharge plan within 24 hours of admission or registration and
complete a discharge plan before the patient is discharged home or transferred
to another facility. This would apply to all inpatients and certain types of
outpatients, including patients receiving observation services, patients who
are undergoing surgery or other same-day procedures where anesthesia or
moderate sedation is used, and emergency department patients who have been
identified by a practitioner as needing a discharge plan. In addition,
hospitals, critical access hospitals, and home health agencies would have to —
Provide discharge instructions to patients who are discharged home
(proposed for hospitals and critical access hospitals only);
Have a medication reconciliation process with the goal of
improving patient safety by enhancing medication management (proposed for
hospitals and critical access hospitals only);
For patients who are transferred to another facility, send
specific medical information to the receiving facility; and
Establish a post-discharge follow-up process (proposed for
hospitals and critical access hospitals only).
Increased Patient Participation in the Discharge Planning Process:
The proposed rule emphasizes the importance of the patient's goals
and preferences during the discharge planning process. These improvements
should better prepare patients and their caregivers to be active partners for
their anticipated health and community support needs upon discharge from the
hospital or post-acute care setting. Hospitals and critical access hospitals
would be required to consider several factors when evaluating a patient's
discharge needs, including but not limited to the availability of non-health
care services and community-based providers that may be available to patients
post-discharge.
In addition, patients and their caregivers would
be better prepared to select a high quality post-acute care provider, since
hospitals, critical access hospitals, and home health agencies would be
required to use and share data, including data on quality and resource use
measures. This results in the meaningful involvement of patients and their
caregivers in the discharge planning process.
“This rule puts the patient and their caregivers at the
center of care delivery,” said CMS Deputy Administrator and Chief Medical
Officer Patrick Conway, M.D., MSc. “Patients will receive discharge
instructions, based on their goals and preferences, that clearly communicate
what medications and other follow-up is needed after discharge, and pertinent
medical information will be communicated to providers who care for the patient
after discharge. This leads to better care, smarter spending, and healthier
people.”
This document is scheduled to be published in the Federal Register
on 11/03/2015 and available online at http://federalregister.gov/a/2015-27840. There is a 60 day
comment period on the proposed rule.