New Discharge Planning Rules Put the Focus on Patients

A new discharge planning rule went into effect Nov. 29, 2019. While new regulations often have providers scrambling to prepare, this one shouldn’t be too heavy of a lift. That’s because a lot of the rule is about mandating what many rural hospitals and CAHs already do as part of their discharge planning process.

According to Modern Healthcare, hospitals and home health agencies will spend an estimated $215 million per year overall to comply with the discharge planning changes, plus $46.5 million in one-time costs. And yes, these new regulations also apply to patients whose status changes from acute inpatient to swing bed services.

CMS acknowledged that one of its reasons for updating the regulations was to bring discharge planning requirements into closer alignment with what hospitals are already doing.

“This final rule empowers patients to be active participants in the discharge planning process and complements efforts around interoperability,” CMS said in its final rule summary.

But the new discharge planning regulation also offers some important changes aimed at improving patient engagement, boosting continuity of care and reducing patient readmissions.

Although seemingly simple on the surface, “the details are always a little more complicated,” says Carolyn St. Charles, RN, BSN, MBA, chief regional clinical officer for HealthTechS3.

Here’s a deeper look into the details of two of the biggest changes in the new regulations.

Information requirements for post-acute care providers

During the public comment period, many commenters lamented the long list of proposed elements that hospitals would have to send to post-acute care providers. The final rule exchanged a rigid list of requirements for a broader statement, requiring that a hospital provide “all necessary medical information pertaining to the patient’s current course of illness and treatment, post-discharge goals of care, and treatment preferences, at the time of discharge, to the appropriate post-acute care services providers and suppliers, facilities, agencies and other outpatient service providers and practitioners responsible for the patient’s follow-up or ancillary care.”

So, what should the information transfer contain? As a start, CMS recommends current diagnosis (including any behavioral health issues of mental health and substance abuse), lab results (including Clostridium difficile and multi-drug resistant organism status, as well as any antibiotic susceptibility testing), and patient functional status. But the list could be longer, but hospitals have discretion to send the most relevant information.

Quality measures and hospital role in the post-acute care provider selection process

Under the new regulations, hospitals are required to assist patients in the selection process by using and sharing data on quality and resource use measures. You’re correct if this sounds familiar, as it’s essentially the discharge planning requirements of the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT ACT). Hospitals can use and share data from CMS’ various post-acute care Compare sites, which have data on functional status, skin integrity, incidence of major falls, as well as resource use, but the final rule does not require hospitals to use a particular data source.

The hospital’s role is to provide “objective data on quality and resources use measures specifically applicable to the patient’s 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.”

So, what about swing beds, which are not required to report data on their performance? One commenter pointed out that this requirement could unduly put swing beds at a disadvantage, since patients won’t have quality data for that option. For now, CMS says it does “not believe that any provider will be disadvantaged with this requirement.”

Make sure you’re up to speed on how these new requirements impact yout discharge planning process. Mark your calendar for Friday, Feb. 7 and make plans to tune into the webinar “New Discharge Planning Requirements—What You Need to Know.” In just an hour, Carolyn St. Charles will help you understand the new regulations and offer practical tips for meeting the new requirements. Register today.