In order to carry out the standardization of post-acute patient assessment data as mandated in the IMPACT Act, CMS announced Oct. 29 its proposal to add a new Condition of Participation (CoP) related to home health discharge planning. The new requirements would be part of a discharge planning overhaul CMS would like to also carry out for hospitals, long-term care hospitals, inpatient rehab facilities and critical access hospitals (CAHs), CMS says in its proposed rule.
 
The IMPACT Act, which “addresses discharge planning, requires the modification of the Conditions of Participation (CoPs) and subsequent interpretive guidance applicable to PAC providers, hospitals, and CAHs at least every 5 years, beginning no later than January 1, 2016.”
 
Comments on the rule must be submitted within 60 days.
 
The discharge planning CoP would require regular reevaluation of patients to identify changes that require modification of the discharge plan, that a doctor responsible for the plan of care be involved in the ongoing process of establishing the discharge plan and that agencies consider the availability of caregiver/support as part of the identification of patients’ discharge needs, CMS says.
 
CMS also would require agencies produce for every patient a discharge summary that has, at minimum, information related to 21 elements, including demographics, procedures, diagnoses, functional status assessments and consultation results.
 
While the intent of the proposed rule to enhance discharge planning for patients appears helpful on its face, these requirements in practice may prove to be an unnecessary burden for agencies already overloaded with regulatory mandates, says Ann Rambusch, president of Rambusch3 Consulting, Georgetown, Texas. It could in essence mean more documentation requirements for agencies that already have an effective discharge process.
 
For more on the proposed rule, check back with HHL.
 
Related link: Read the proposed rule here: http://tinyurl.com/qd3z77v.