Today the Centers for Medicare & Medicaid Services (CMS) published a proposed rule that would modify the discharge planning conditions of participation (COPs) for hospitals, including long-term care hospitals and inpatient rehabilitation facilities, critical access hospitals, and home health agencies (HHAs). The proposed rule would implement the discharge planning requirements of the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act). The proposed changes are designed to promote “consumer-centered health care” by requiring the affected provider types to, among other things, solicit patient input with respect to discharge planning, and to share information among relevant parties, including the patents/caregivers, the physician, and the post-acute provider to whom the patient is discharged if applicable.
According to a CMS fact sheet, 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. They would also improve consumer transparency and beneficiary experience during the discharge planning process, consistent with the requirements of the IMPACT Act. Some of the most significant proposals include: a requirement for hospitals to prepare a written discharge plan for all inpatients and certain categories of outpatients, and specific written discharge instructions for all patients; a requirement that hospitals assist patients with selecting a post-acute provider by using and sharing data (including post acute provider data on quality measures and data on resource use measures) as relevant and applicable to the patient’s care goals and preferences; a requirement to consider and address in the discharge plan what care resources that are available to the patient, such as caregivers and community-based care; a requirement for hospitals to perform a medication reconciliation for all patients discharged to a residential setting, in order to ensure that all prescription and over-the-counter medications prescribed during or prior to hospitalization are accounted for; and a requirement for HHAs to furnish a transfer summary that contains specific information to a receiving provider.
CMS estimates that the rule would impose first year costs of $454 million and recurring costs of about $396 million a year, with a majority of these costs impacting HHAs. Comments on the rule will be accepted until January 4, 2016.