Knowledge Base Article

On Friday May 17, 2013, the Centers for Medicare and Medicaid Services (CMS) released a memorandum to State Survey Agency Directors containing revisions to Appendix A – Interpretive Guidelines for 42 CFR 482.43, Discharge Planning. The memorandum instructs that the revisions are effective immediately.

Under §482.43 Condition of Participation: Discharge Planning the revisions indicate that “reducing the number of preventable hospital readmissions is a major priority for patient safety, and holding hospitals accountable for complying with the discharge planning CoP is one key element of an overall strategy for reducing readmissions.”

Within this 39-page document are Advisory Boxes that “display successful practices currently found throughout the industry in the area of care transitions.” The Advisory Boxes are not hospital compliance requirements rather suggestions for process improvement. One Advisory Box provides examples of patient discharge planning tools that includes the following links:

• Medicare’s “Your Discharge Planning Checklist” (available at http://www.medicare.gov/publications/pubs/pdf/11376.pdf,
• Agency for Healthcare, Research and Quality’s (AHRQ) “Taking Care of Myself: A Guide for When I Leave the Hospital” (available at http://www.ahrq.gov/patients-consumers/diagnosis-treatment/hospitals-clinics/goinghome/goinghomeguide.pdf; and
• Consumers Advancing Patient Safety (CAPS) “Taking Charge of Your Healthcare: Your Path to Being an Empowered Patient Toolkit” (available at http://www.patientsafety.org/page/transtoolkit.

This memorandum also provides clarification for providing a patient list of available Home Health or Skilled Nursing Facilities. (See Survey Procedures §482.43(c)(6), §482.43(c)(7) & §482.43(c)(8):

• “Review a sample of cases of patients discharged to HHAs or SNFs to determine if, when applicable, the hospital provided the patient with lists of Medicare-participating HHAs or SNFs. In making this determination:
•  Is there documentation of a list of multiple HHAs or SNFs being provided (including electronically) to the patient? If not, is there documentation for an acceptable rationale for providing only one option, e.g., the patient’s home is included in the service area of only one Medicare-participating HHA that requested to be included on hospital lists, or there is only one Medicare-participating SNF in the area preferred by the patient?
• Ask to see examples of lists of HHAs and SNFs provided to patients prior to discharge.”

MMP, Inc. encourages Case Management and Discharge Planning Staff to review the entire memorandum at: http://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-13-32.pdf