The Centers for Medicare and Medicaid Services (CMS) Nov. 3 released the Revisions to Requirements for Discharge Planning for Hospitals, Critical Access Hospitals, and Home Health Agencies proposed rule. Comments on the rule are due by Jan. 4, 2016.
The proposed rule modernizes the discharge planning requirements for the Medicare program. CMS outlines the reasoning for updating the requirements to reflect current practice and to establish a more robust transition process from acute care to post-acute and/or home. The proposed revisions focus on ensuring all patients have a comprehensive discharge plan and patients and their caregivers are actively engaged in the process.
The rule also implements the discharge planning requirements in the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act, P.L. 113-185). The IMPACT Act requires the Conditions of Participation (CoPs) that focus on discharge planning to be updated every five years starting in January 2016. It also requires that hospitals take into account quality and resource use measures to assist patients and their families in the selection of post-acute facilities.
While many of the proposed revisions reflect current practice, there are a few new requirements that may impact providers, including: all inpatients and certain categories of outpatients must have a discharge plan developed within 24 hours of admission or registration; requiring hospitals to establish a post-discharge follow-up process for patients discharged home; and providing quality and resource use data on post-acute care (PAC) facilities to patients and families during the selection process.
CMS is also soliciting comments on the use of state’s Prescription Drug Monitoring Program (PDMP) and whether or not providers should be required to consult the PDMP in reviewing a patient’s co-morbidities and as part of the medication reconciliation process.
The Impact Analysis estimates the proposed rule to be economically significant. CMS welcomes comments on their assumptions for impact and whether or not implementing the new requirements would result in additional costs to providers and patients that are not already accounted for in the analysis.