Discharge Planning Conditions of Participation Final Deadline Approaching

Final rule becomes effective Friday, Nov. 29, 2019

EDITOR’S NOTE: The following are edited remarks by Mary Beth Pace, the author who was a panelist on Monitor Mondays Nov. 25, reporting on how Trinity Health is preparing to implement the final rule on discharge planning conditions of participation from the Centers for Medicare & Medicaid Services (CMS).

I remember back when CMS started work on the Improving Medicare Post-Acute Care Transformation Act (IMPACT) Act of 2014. We sat in a room to go over the specifics. I remember the health information management (HIM) director sitting next to me worrying about the ability to provide patients access to their own electronic medical records (EMRs) – and also worrying about physician DC summaries and timeliness. I read over the changes they were proposing in discharge planning conditions of participation, and felt at that time we would meet all of them:

• Timeliness: We have a policy that all patients are assessed for DCP needs within 24 hours of arrival. Some call this the initial assessment, some call it “meet and greet.” Regardless of the name of the assessment, all of our patients are seen.
• Sharing of the skilled nursing facility (SNF) and home health agency (HHA) quality performance: We have been working with SNFs and HHAs over the last four years, and are sharing star rating and readmission scores, information about their quality programs, as well as an indication of whether they are owned by us. We call them our preferred providers. The actual name of the document provided to patients is the Quality of Care Profile.

Fast forward to today:

• CMS issues the decree in September and asks for implementation on Black Friday. The irony of that decision did not go overlooked.
• CMS not only goes as far as to say we cannot call the providers “preferred;” they also say we have to now provide information for all agencies a patient/family wants to see – OK, so we will adjust our terminology and use the word “performance,” but “all” providers must be included? Really? Do you know the burden that will put on some of our hospitals in densely populated areas? And if we do not provide those agencies’ information the first time to the family, are they able to drag their feet and ask about other agencies that they did not ask for the first time? Avoidable delays, here we come!! I shiver when I think of areas like Chicago, Philadelphia, and New York.

• Some ideas to combat this are as Ronald Hirsch, MD spoke about in his opening on Monitor Mondays: Chromebooks, for example. We were actually thinking about laminating some lists to have them available on the unit. I worry either way here about infection control, but we will need to do something if we ever get the detail for the conditions of participation? I still have not seen anything yet – has anyone else?

• No one thought of the administrative burden this causes. I have never heard a hospital say “I have enough case managers or social workers, and we are just on top of every single transition and we never have avoidable delays.” 

Unfortunately, the media is causing worries and so many sensational ideas. I wonder who is putting this out? I wonder who lobbied for these changes? I wonder if the SNF/HHA groups will benefit or be hurt, in the long run. They already have so many changes in the Patient-Driven Payment Model (PDPM) world, for SNFs, and the HHA changes coming in January, but let’s just drive a few more nails into the coffin.

So what should we do?

• Until guidelines are issued, we will hold off adding more quality information to the complete list. The one step we will take is to take “preferred” out of our vocabulary and replace it with “performance” or “high-performing.”
• If we need to provide laptops/Chromebooks to each patient to review quality information, we could have a huge infection control risk on our hands. We are actually thinking about laminating the pages and having a few per unit.
• We are also looking into the media contract for our education channels to see if they can put something on the air. Some of our hospitals have a little intro to CM/SW on the channel, but this will take some time. 

And of course, we will work on inpatient rehabilitation facilities (IRFs) and long-term care facilities (LTCFs) – just as soon as we see guidance on quality measures and resource use measures.