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AAMC Comments on CMS Discharge Planning Proposed Rule

January 8, 2016

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PRESS CONTACTS
Jennifer Faerberg, Director, Clinical Transformation Unit

The AAMC Jan. 4 submitted a comment letter on the Centers for Medicare and Medicaid Services (CMS) Revisions to Requirements for Discharge Planning for Hospitals, Critical Access Hospitals, and Home Health Agencies Proposed Rule [see Washington Highlights, Nov. 20, 2015].

The rule proposes changes to the discharge planning requirements in the Conditions of Participation (CoPs). The goal is to provide more robust discharge planning, incorporating patients and their caregivers, ultimately aiming to reduce readmissions and patient complications.

AAMC supports the move towards robust discharge planning and highlighted the work of our member institutions in developing innovative approaches to discharge planning and patient education.

The AAMC provides comments on a number of the new requirements, most notably the new requirement to provide full discharge plans to all inpatients and a subset of outpatients as well as establishing a post-discharge follow-up process for the same patient population. The letter calls for flexibility in implementation and allowing for risk assessment and patient’s medical and social needs to determine what is in the best interest of the patient.

Discharge planning and post-discharge follow-up does not suit a one-size fits all approach. The AAMC also calls for alignment with Meaningful Use regarding the required data elements to be shared with patients and providers. AAMC also countered CMS’ impact analysis of the rule and highlighted how the new requirements will have a significant financial impact on staffing and other resources.

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