FHA Comments Discharge Planning NPRM
January 4, 2016
Page 1
Submitted electronically
Andy Slavitt
Acting Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
P.O. Box 8010
Baltimore, MD 21244
Re: CMS 3317-P, Medicare and Medicaid Programs; Revisions to Requirements for Discharge Planning for Hospitals, Critical Access Hospitals, and Home Health Agencies (Vol. 80, No. 212, Nov. 3, 2015)
Dear Mr. Slavitt:
On behalf of our over 200 hospital and health system members, the Florida Hospital Association (FHA) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) proposed rule on revisions to requirements for discharge planning for hospitals, critical access hospitals (CAHs), inpatient rehabilitation facilities (IRFs), and home health agencies (HHAs).
While the FHA generally supports the rule and agrees with CMS’s goal for hospitals to have comprehensive, multi-disciplinary discharge planning processes that incorporate evidence-based practices, patient-centeredness and community engagement, we are concerned that the implementation of some of the proposed provisions would be complex and expensive. We are concerned that, as proposed, the rule would require hospitals to add staff, especially during the weekend and after-hours; train or retrain new and existing staff; change practitioner and administrative workflow and procedures; and alter electronic health record (EHR) systems to align with the proposed standards.
In the proposed rule, hospitals and CAHs would be required to create discharge plans for all inpatients as well as some outpatients, including observation patients; same-day patients receiving anesthesia or moderate sedation; emergency department (ED) patients identified by ED practitioners as needing a discharge plan; and other categories of outpatients recommended by the medical staff and specified in the hospital’s/CAH’s discharge planning policies approved by the governing body.
A strong discharge plan ensures that the patient will experience a smooth care transition to the next care setting and helps avoid post-hospital complications as well as readmissions. Effective discharge planning assures that as patients leave the hospital, they and/or their caregivers have a good understanding of the patient’s medical condition, what and how medication should be taken, how the patient should be cared for at home, and what follow-up care will be needed, if any.
We urge CMS to adopt recommendations from the American Hospital Association that include the following:
(1) change the scope of the proposed requirements so that either discharge plans or discharge instructions can be provided in certain instances in order to better align discharge planning efforts with the needs of each patient;
(2) revise the proposal to require that a discharge plan be developed within 24 hours of admission or registration to state that it must begin in a timely manner and be an ongoing process during the patient stay;
(3) provide flexibility to address the lack of community resources in some areas; and
(4) revisitthe cost estimates to reflect the true impact of increasing the discharge planning requirements.
In addition, we urge CMS to establish an effective date that is two years from the date of the final rule. We believe this timeframe would give hospitals and other impacted entities enough time to make needed changes, including working with their EHR vendors to incorporate the changes before the effective date.
We also ask that CMS clarify the use of a comprehensive discharge plan versus the use of discharge instructions. While we agree that all inpatients should have a discharge plan, as well as some, but not all, observation and same-day patients who receive anesthesia or moderate sedation, patients undergoing many outpatient diagnostic procedures likely require a clear, comprehensive set of discharge instructions, but not a full discharge evaluation and plan. We believe that the policies and procedures of the hospital developed in conjunction with the medical staff should delineate the appropriate levels of discharge planning required for various types of patients.
Thank you again for the opportunity to provide these comment. If you have any questions, please contact at or (407) 841-6230.
Sincerely,
Kathy Reep
Vice President/Financial Services