Despite the fact that swing beds were first authorized in 1980, there have been considerable changes to the program in just the past few years. The Conditions of Participation (CoPs) changed substantially in October 2018, a new reimbursement model for PPS hospitals with a distinct part swing bed unit was released in 2019, followed by more changes just this past February. The changes that were published in the CoPs in February were first published in the Federal Register in November of 2019.
October 2018 swing bed program changes
- Patient’s right to choose a physician
- Providing the patient information on how to contact their providers
- Timelines for reporting abuse and misappropriation of property
- Clarification about review and inclusion of a PASARR in the plan of care
- Provision of culturally competent and trauma informed care
- Disciplines that must participate in developing the Plan of Care
- Medication reconciliation at discharge
- Notification of the ombudsman at discharge
October 2019 swing bed program changes for PPS Hospitals with a distinct part unit
- Introduction of Patient-Driven Payment Model (PDPM) methodology
- Introduction of a variable per diem adjustment
February 2020 swing bed program changes
- Provide a choice of post-acute care providers including resource and quality data
- Deletion of the requirement to provide activities by a qualified professional
- Deletion of the patient’s right to work
- Deletion of the requirement to employ a full-time social worker if fewer than 120 beds
That’s a lot of changes in a short amount of time, but their net impact should make providing swing bed services easier and more profitable for hospitals—if swing bed providers can get up to speed on them.
Regular, systematic review of policies and procedures is key
Carolyn St. Charles, Chief Clinical Officer of HealthTechS3, is presenting the upcoming webinar, Keeping Your Swing Bed Program Survey Ready, to review recent changes to swing bed rules and regulations and provide practical tips to help rural and critical-access hospitals (CAHs) stay current on what’s required.
When auditing policies and procedures as well as patient admission and discharge notifications, St. Charles recommends breaking down the review into four manageable sections—pre-admission, admission, continued stay and discharge.
“Compare each process to the requirements and make note of any inconsistencies in a gap analysis,” she says. “That document then becomes the basis for developing a plan of correction.”
St. Charles recommends assembling a multi-disciplinary team to help complete the audit. The team should mirror the stakeholders involved in providing the swing bed services—physicians, case managers, nurses, nursing assistants, social workers, physical therapists, occupational therapists, speech therapists, dietitians or dietary managers and pharmacists. She also recommends including a representative from the business office and/or health information management departments to help identify issues related to admission or billing.
The gap analysis isn’t a standalone document. In fact, St. Charles says, “It doesn’t even have value, and is a waste of effort,” without the subsequent development and implementation of a plan of correction.
There are five key questions to address in the plan of correction:
- What are you trying to fix?
- What needs to be done?
- Who is responsible?
- When does it need to be done?
- How will you measure compliance?
The swing bed-QAPI connection
In addition to reviewing the swing bed program for gaps relative to regulatory requirements, it’s also important to review how swing bed processes can be improved. With CAHs being required to meet new quality assessment and performance improvement (QAPI) requirements as a condition of their participation in Medicare, St. Charles says hospitals with swing bed programs should consider using a swing bed improvement project to satisfy the upcoming March 2021 QAPI requirement. This is another topic she’ll cover in her Nov. 6, webinar. Reserve your spot today.