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UPDATE: Centers for Medicare and Medicaid Services (CMS) Revisions Christy Rakoczy

June 3rd, 2013

CMSOn May 17, 2013 the Centers for Medicare and Medicaid Services (CMS), a division of the Department of Health and Human Services, issued a Memorandum in regards to the revision of the State Operations Manual. The revision applies to the State Operations Hospital Appendix A, Interpretive Guidelines for Hospitals, Condition of Participation: Discharge Planning, in order to “update the guidance for the discharge planning Condition of Participation.”

The revisions to Appendix A include interpretive guidelines that are italicized and written in red to denote the portion of the appendix that has been updated. The sections of Appendix A that are affected are:

  • 482.43: The hospital’s policies and procedures must be specified in writing.
  • 482.43(a): The hospital must identify at an early stage of hospitalization all patients who are likely to suffer adverse health consequences upon discharge if there is no adequate discharge planning.
  • 482.43(b) (1): The hospital must provide a discharge planning evaluation the patients identified in paragraph (a) of this section, and to other patients upon the patient’s request, the request of a person acting on the patient’s behalf, or the request of the physician.
  • 482.43(b)(2)A: registered nurse, social worker, or other appropriately qualified personnel must develop, or supervise the development of, evaluation.
  • 482.43(b)(5):The hospital personnel must complete the valuation on a timely basis so that appropriate arrangements for post-hospital care are made before discharge, and to avoid unnecessary delays in discharge.
  • 482.43(b): The hospital… must discuss the results of the evaluation with the patient of individual acting on his or her behalf.
  • 482.43(b)(6): [The hospital must] include the discharge planning evaluation in the patient’s medical record for use in establishing an appropriate discharge plan.
  • 482.43(c)(1): A registered nurse, social worker, or other appropriately qualified personnel must develop, or supervise the development of, a discharge plan if the discharge planning evaluation indicates a need for a discharge plan.
  • 482.43(c)(2): In the absence of a finding by the hospital that a patient needs a discharge plan, the patient’s physician may request a discharge plan. In such a case, the hospital must develop a discharge plan for the patient.
  • 482.43(c)(3): The hospital must arrange for the initial implementation of the patient’s discharge plan.
  • 482.43(c)(4): The hospital must reassess the patient’s discharge plan if there are factors that may affect continuing care needs or the appropriateness  of the discharge plan.
  • 482.43(c)(6): The hospital must include in the discharge plan a list of HHAs or SNFs that are available to the patient, that are participating in the Medicare program, and that serve the geographic area (as defined by the HHA) in which the patient resides, or in the case of a SNF, in the geographic area requested by the patient. HHAs must request to be listed by the hospital as available.
  • 482.43(d): The hospital must transfer or refer patients, along with necessary medical information, to appropriate facilities, agencies or outpatient services, as needed, for follow-up or ancillary care.
  • 482.43(e): The hospital must reassess its discharge planning process on an on-going basis. The reassessment must include a review of discharge plans to ensure that they are responsive to discharge needs.

Additionally, blue boxes are also included in which there are advisories for discharge planning staff. Hospital compliance is not determined by adherence, or lack thereof, to the suggestions in the blue boxes. Instead, these boxes should be viewed as resources with information that could be helpful. The type of information found in those boxes may be practices that have been successful in improving readmission rates in other hospitals, or which have proved helpful in somehow bettering the discharge process.

Additionally, the Automated Survey Processing Environment Tags (referred to as ASPEN Tags) for discharge were reorganized; some were completely removed, in 2012. This document reflects those changes. There is a table at the end of the document that cross-references the old and new tags.

The purpose of the document and its revisions, overall, is to educate discharge planners and other hospital staff on how to better address the discharge process. This is part of the overall attempt to improve readmissions rates in all hospitals.

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