Changes to the Home Health Conditions of Participation; 5. (Medicare Advantage) patient admitted to or discharged from an IRF on or after October 1, 2009. Enhanced content is provided to the user to provide additional context. result, it may not include the most recent changes applied to the CFR. Does documentation support that the patients acute medical condition has been appropriately diagnosed and treated such that it is not a barrier to participation in the intensive therapies of the IRF? 2022 SunStone Consulting LLC. Learn more. Hospitals. Consider one of the subscription options below to receive full access to this article and many more. The discharge plan must be updated, as needed, to reflect these changes. Under the Final Rule, HHAs are also required to develop and implement an effective discharge planning process. Understand these two elements of Medicare Advantage plans: The discharge planning evaluation is not required to include information on the availability of home health services through individuals and entities that do not have a contract with the organization. (8) The hospital must assist patients, their families, or the patient's representative in selecting a post-acute care provider by using and sharing data that includes, but is not limited to, HHA, SNF, IRF, or LTCH data on quality measures and data on resource use measures. IRF Conditions of Participation Free-standing facility or distinct unit of hospital Beds cannot be co-mingled with acute care patients Medical Director who is MD or DO with minimum two years trainingin rehabilitation services View the most recent official publication: These links go to the official, published CFR, which is updated annually. The survey process focuses on a hospitals performance of patient-focused and organizational functions and processes. If you have any questions, please contact Vonda Moon, Principal at vondamoon@sunstoneconsulting.com, or Laura Ehrlich, Senior Clinical Specialist at lauraehrlich@sunstoneconsulting.com. The office is open 8:00AM - 8:00PM M-F Eastern Time. This web site is designed for the current versions of On December 11, 2017, the Centers for Medicare and Medicaid Services (CMS) published MLN Matters Special Edition 17036 (SE 17036), Inpatient Rehabilitation Facility (IRF) Medical Review Changes. Evaluations also should be provided to other patients at the request of the patient, the person acting on the patients behalf, or the physician. 3. All Rights Reserved. site when drafting amendatory language for Federal regulations: The hospital must ensure that the post-acute care data on quality measures and data on resource use measures is relevant and applicable to the patient's goals of care and treatment preferences. Medicare beneficiaries treated in IRFs must meet stringent admissions criteria to ensure that IRF care is necessary. For further information or questions about the Final Rule, please contact any member of Kutak Rocks National Healthcare Practice Group. Compliance with Conditions of Payment for Inpatient Rehabilitation Facilities require the following: In contrast to Conditions of Payment, Conditions of Participation are rules that typically relate to the quality of care provided. The first thing to consider is focusing on including the patients goals and preferences in the planning process. (1) IRFs that do not meet the requirement in paragraph (b) of this section for a program year will receive a written notification of non-compliance through at least one of the following methods: The CMS designated data submission system, the United States Postal Service, or via an email from the Medicare Administrative Contractor (MAC). Although the discharge planning requirements apply to psychiatric hospitals, psychiatric hospitals will still be required to meet additional special provisions, special medical record requirements, and special staff requirements that are not discussed in the Final Rule. (vi) Reason(s) for requesting reconsideration. At this time, choice lists need only be given for patients transferring to home health or to a SNF. switch to eCFR drafting site. In other words, discharge planning allows for a smooth move for the patient across the continuum, and at all transition points. Be consistent with Section 1802 (Freedom of Choice) by not specifying or limiting qualified providers. booklet. Finally, the Final Rule updates one provision regarding patient rights in hospitals, which is intended to promote innovation and flexibility in the improvement of patient care and ensures a patients right to access his or her own medical information from a hospital. Electronic Code of Federal Regulations (e-CFR), CHAPTER IVCENTERS FOR MEDICARE & MEDICAID SERVICES, DEPARTMENT OF HEALTH AND HUMAN SERVICES, PART 412PROSPECTIVE PAYMENT SYSTEMS FOR INPATIENT HOSPITAL SERVICES, Subpart PProspective Payment for Inpatient Rehabilitation Hospitals and Rehabilitation Units. All rights reserved. Third, the discharge plan must identify any HHA or SNF to which the patient is referred in which the hospital has a disclosable financial interest and any HHA or SNF that has a disclosable financial interest in a hospital under Medicare. Financial Disclosure: Author Melinda Young, Author Jeanie Davis, Editor Jill Drachenberg, Editor Jonathan Springston, Editorial Group Manager Leslie Coplin, and Nurse Planner Toni Cesta, PhD, RN, FAAN, report no consultant, stockholder, speakers bureau, research, or other financial relationships with companies having ties to this field of study. (2) A discharge planning evaluation must include an evaluation of a patient's likely need for appropriate post-hospital services, including, but not limited to, hospice care services, post-hospital extended care services, home health services, and non-health care services and community based care providers, and must also include a determination of the availability of the appropriate services as well as of the patient's access to those services. 888-421-1801 Need To Know About Inpatient Rehab Guidelines? As a In contrast to Conditions of Payment, Conditions of Participation are rules that typically relate to the quality of care provided. March 1, 2020 The Conditions of Participation for Discharge Planning: Current Rules and 2020 Updates March 1, 2020 In 2015, CMS introduced proposed rules for discharge planning. Case managers must determine the patients capacity for self-care, or the likelihood of needing home care services. 482.43 Condition of participation: Discharge planning. In addition, IRFs must complete a patient assessment instrument in accordance with 412.606 for all other patients, . You have reached your article limit for the month. Operationalizing CMS Guidance From A Patient Perspective, What is in store for 2019 OPPS? Standard: Requirements related to post-acute care services. Participation in IMRF is not optional for employees who meet the 600-hour standard. (2) The HHA must comply with requests for additional clinical information as may be necessary for treatment of the patient made by the receiving facility or health care practitioner. The hospital must identify in its discharge planning policy the qualified personnel who will be involved in the discharge planning process and must execute their discharge planning process in accordance with their policies. (vii) Date when the IRF believes it will be able to again submit IRF QRP data and a justification for the proposed date. In summary, SE 17036 illustrates the need for careful, well documented post-acute care planning, which may put the onus back on the acute care facility to provide the appropriate supporting documentation. If an employee meets IMRF qualification standards, he or she must participate; this participation cannot be excused by the employer. Proposed OPPS Reimbursement and Policy Update, Take a Deep Breath - Effectively Managing Pulmonary Rehabilitation Program Requirements, Postoperative Visit Reporting Requirement Commences July 1, 2017 for Nine States, CMS Proposed Rules for Fiscal Year 2018 Inpatient Prospective Payment System, Dont Waste Drug Revenue Application of JW Modifier, "March Madness": Take the offense! A discharge planning evaluation must include an evaluation of a patients likely need for appropriate post-CAH services, including, but not limited to, hospice care services, post-CAH extended care services, home health services, and non-health care services and community-based care providers. The goal of a hospital survey is to determine if the hospital is in compliance with the Conditions of Participation set forth in 42 CFR Part 482. CMS says other personnel can complete the assessment under the supervision of the nurse or social worker. As of today, this audit remains on the OIG work plan with an expected release date in FY 2018. CMS has also implemented requirements regarding patient transfers from CAHs. Hospitals may not frustrate the legitimate efforts of individuals to gain access to their own medical records and must actively seek to meet such requests as quickly as its record keeping system permits. Amount of Separation Refund. Comments or questions about document content can not be answered by OFR staff. We do encourage hospitals to provide any information regarding PAC providers that provide services that meet the needs of the patient. Additional Information (4) Email is the only form of submission that will be accepted. CMS wants proof that the increased expense of IRF coverage is appropriate and cost effective for the patient prior to entering the IRF. For that reason, the discharge planning CoPs do not include requirements specific to individual practitioner categories. Although we are teaching, the Office is closed Major US Holidays and Weekends. IRF, or LTCH data on quality measures and data on resource use measures. Get unlimited access to our full publication and article library. The discharge planning process must require regular re-evaluations of the patients condition to identify changes that may require modification of the discharge plan and all evaluations and plans must be included in the patients medical record. Include in the evaluation the patients need for appropriate post-hospital services, and the availability of such services. Conditions of Participation A condition of participation is a much broader concept, and, depending on which federal circuit a case is brought in, it may not trigger False Claims Act liability. You are using an unsupported browser. CMS clarified that providers may use appropriate practitioners (including non-physician practitioners) that they believe will effectively conduct a patients discharge planning process. Choosing an item from (2) The hospital, as part of the discharge planning process, must inform the patient or the patient's representative of their freedom to choose among participating Medicare providers and suppliers of post-discharge services and must, when possible, respect the patient's or the patient's representative's goals of care and treatment preferences, as well as other preferences they express. (3) An IRF must meet or exceed both thresholds to avoid receiving a 2 percentage point reduction to their annual payment update for a given fiscal year, beginning with FY 2016 and for all subsequent payment updates. Without documentation of these tasks in the medical record, case managers will not receive will not get credit for completing them. Learn more, New Research Suggests Treating Traumatic Brain Injury as a Chronic Illness, Anesthesiologists Call on Patients to Stop Taking Trendy Drug Before Surgery, AAP Advocates Placing Outpatient Pharmacies in Emergency Departments, TJC Healthcare Equity Certification Launches July 1. Use quality and resource measures relevant to patients goals of care and treatment preferences in the discharge planning process. So, what has changed? This content is from the eCFR and is authoritative but unofficial. Medicare Unveils Diabetes Prevention Plan, How to "research" your "clinical research" billing compliance. Kutak Rock LLP is ISO 27001:2013 certified. CMS initially proposed several other requirements for HHAs to implement in the discharge planning process; however, many of these areas were subsequently addressed in the 2017 Medicare and Medicaid Program: Conditions of Participation for Home Health Agencies final rule. Are they likely to eventually be placed in a SNF? In addition, we expect hospitals to comply with requirements in 482.43(c) and inform the patient and/or the patients representative of their freedom to choose among participating Medicare providers and suppliers of post-discharge services, while not specifying or otherwise limiting the qualified providers or suppliers that are available to the patient. As with hospitals, there is not a specific list of medical information finalized that CAHs are required to send to the receiving facility, but CMS again emphasizes the importance in including all necessary medical information relevant to the patients care and treatment. Contact an IMRF New Account Representative for more detailed information about joining IMRF. The Final Rule was published on September 30, 2019 and is available here. (5) Email is the only form of submission that will be accepted. The intent was to determine whether IRFs have billed claims in compliance with Medicare documentation and coverage requirements (W-00-15-35730). Microsoft Edge, Google Chrome, Mozilla Firefox, or Safari. Focus on patients goals of care and treatment preferences. This month, we will discuss the current rules, the proposed rules, and the final rules published in 2019. user convenience only and is not intended to alter agency intent (1) A hospital must inform each patient, or when appropriate, the patient's representative (as allowed under State law), of the patient's rights, in advance of furnishing or discontinuing patient care whenever possible. Medical Dictionary, 2009 Farlex and Partners. The pension benefit is based on a set formula determined by the Illinois Pension Code and guaranteed by the Illinois Constitution. While you can provide choices for other discharge destinations, you have no regulatory requirement to do so. Today, the CoPs are managed under the Department of Health and Human Services. (b) Standard: Discharge or transfer summary content. (b) Standard: Discharge of the patient and provision and transmission of the patient's necessary medical information. A hospital must protect and promote each patient's rights. will bring you to those results. If you already have a subscription to this publication, please log in to view the full article. The hospital must have an effective discharge planning process that focuses on the patient's goals and treatment preferences and includes the patient and his or her caregivers/support person(s) as active partners in the discharge planning for post-discharge care. For patients discharged home and referred for HHA services or for those patients transferred to a SNF for post-hospital extended care services, or transferred to an IRF or LTCH for specialized hospital services, CMS has set down several additional requirements: CMS provided a significant amount of commentary regarding the requirements that the hospital provide a list of PAC providers and inform the patient, or the patients representative, of the freedom to choose among these providers. citations and headings 154/Monday, August 10, 2020/Rules and Regulations 48425 TABLE 1COST AND BENEFIT Provision description Transfers FY 2021 IRF PPS payment rate up-date. For DSR inquiries or complaints, please reach out to Wes Vaux, Data Privacy Officer, In the FY 2017 work plan, the OIG announced a new issue, Case Review of Inpatient Rehabilitation Hospital Patients Not Suited for Intensive Therapy. The hospitals policies and procedures must be specified in writing. Pressing enter in the search box For information on new subscriptions, product (1) Any discharge planning evaluation must be made on a timely basis to ensure that appropriate arrangements for post-hospital care will be made before discharge and to avoid unnecessary delays in discharge. Inpatient Rehab Guidelines Get proper inpatient rehab guidelines before admitting into a drug rehab facility. The new rules for discharge planning went into effect on Nov. 29, 2019, which represents federal fiscal year 2020. 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We believe that hospitals, HHAs and CAHs will be in compliance with this requirement if they present objective data on quality and resource use measures specifically applicable to the patients goals of care and treatment preferences, taking care to include data on all available PAC providers, and allowing patients and/or their caregivers the freedom to select a PAC provider of their choice. This should include a review of discharge plans to ensure they are appropriate for patient needs. Please do not provide confidential If you work for a Federal agency, use this drafting Centers for Medicare & Medicaid Services, Department of Health and Human Services, https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-G/part-484/subpart-B/section-484.58. (2) CMS may remove a quality measure from the IRF QRP based on one or more of the following factors: (i) Measure performance among IRFs is so high and unvarying that meaningful distinctions in improvements in performance can no longer be made; (ii) Performance or improvement on a measure does not result in better patient outcomes; (iii) A measure does not align with current clinical guidelines or practice; (iv) The availability of a more broadly applicable (across settings, populations, or conditions) measure for the particular topic; (v) The availability of a measure that is more proximal in time to desired patient outcomes for the particular topic; (vi) The availability of a measure that is more strongly associated with desired patient outcomes for the particular topic; (vii) The collection or public reporting of a measure leads to negative unintended consequences other than patient harm; (viii) The costs associated with a measure outweigh the benefit of its continued use in the program. Hospitals must also include a determination of the availability of the appropriate services as well as of the patients access to those services.
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