Compliance is mandatory, but data from CMS remains unavailable at this time.
The discharge planning day of reckoning is today, Black Friday, Nov. 29, 2019 – and yet, as of this reporting, the only source of data, the Centers for Medicare & Medicaid Services (CMS) Compare website, still has no skilled nursing facility (SNF) resource use data.
According to Ronald Hirsch, MD, there is another flaw in the final rule that has yet to be rectified. One of the required data elements is resource use.
“If the patient requires inpatient rehabilitation facility (IRF) care or long-term acute care hospitalization (LTACH), the only way for the patient to access that data is either by having the patient or family go online and look at the data on the website, or print out the data for each facility individually,” Hirsch said during his appearance on Monitor Mondays this past Monday. “The website does have a feature that allows you to compare three facilities side by side, but if you print that out, the resource use data does not appear. What does this mean? If you are a Chicago hospital and your patient needs inpatient rehab, you would need to print out 100 pages to provide the patient all the information they are required to receive.”
This situation has led Hirsch to conclude that the only way to meet this requirement is electronically, noting that there are several vendors that have solutions, some of which are free. But hospitals can also refer patients and their families to the CMS websites.
“The pages can be viewed on a phone, but it takes a lot of scrolling,” Hirsch cautioned. “For those who do not have a laptop, perhaps your IT department can buy a few $99 Chromebooks or tablets for use by patients, checking with your infection control departments to ensure you don’t spread pathogens.”
Since most communities have a number of SNFs, and even more have home care agencies, hospitals might want to provide a printed list that simply indicates the star ratings to at least allow the patient to narrow down their choices.
“And remember,” Hirsch added, “you can also indicate any facilities that offer special expertise or meet specific cultural needs. You must indicate any SNFs or home health agencies where the hospital has a financial interest, and you cannot designate any as preferred.”
When CMS was contacted about a possible delay in enforcement, a representative reported that to their knowledge there are no plans for such, adding that sub-regulatory guidance is not expected until spring, 2020. Hirsch remarked that since the surveyors do not have updated survey guidelines from CMS, it would be difficult for them to survey a facility and cite them based on the new regulation.
“But that should not stop every hospital from updating their discharge planning policies and doing their best to comply,” Hirsch added. “Compliance is not optional.”
EDITOR’S NOTE: The author of this article used AI-assisted tools in its composition, but all content, analysis, and conclusions were based on the author’s professional
The Centers for Medicare & Medicaid Services (CMS) operates a surveillance platform called the Fraud Prevention System (FPS) that analyzes Medicare claims across the full
Please log in to your account to comment on this article.
Gain clarity and confidence in OB‑GYN coding with this expert‑led webcast featuring Stacey Shillito, CDIP, CPMA, CCS, CCS‑P, CPEDC, COPC. You’ll learn how to apply global maternity package rules accurately, select the right CPT codes for procedures and visits, and identify documentation gaps that lead to denials. With practical guidance and real examples, this session helps you strengthen compliance, reduce audit risk, and ensure accurate reimbursement for women’s health services.
Uncover essential coding insights with nationally recognized coding authority Kay Piper, RHIA, CDIP, CCS. Through ICD10monitor’s interactive, on‑demand webcast series, Kay walks you through the AHA’s 2026 ICD‑10‑CM/PCS Quarterly Coding Clinics, translating each update into practical, easy‑to‑apply guidance designed to sharpen precision, ensure compliance, and strengthen day‑to‑day decision‑making. Available shortly after each official release.
Uncover critical guidance on the ICD-10-CM/PCS code updates. Kay Piper reviews and explains ICD-10-CM/PCS coding guidelines in the AHA’s fourth quarter 2026 ICD-10-CM/PCS Coding Clinic in an easy to access on-demand webcast.
Uncover critical guidance on the ICD-10-CM/PCS code updates. Kay Piper reviews and explains ICD-10-CM/PCS coding guidelines in the AHA’s third quarter 2026 ICD-10-CM/PCS Coding Clinic in an easy to access on-demand webcast.
Federal auditors are intensifying their focus on inpatient psychiatric facilities, using advanced data analytics to spotlight outliers and pursue high‑dollar repayments. In this high‑impact webcast, Michael Calahan, PA, MBA, Compliance Officer and V.P., Hospital & Physician Compliance, breaks down what regulators are really targeting in IPF-PPS admissions, documentation, treatment and discharge planning. Attendees will learn practical steps to tighten processes, avoid common audit triggers and protect reimbursement and reduce the risk of multimillion-dollar repayment demands.
In this timely session, Stacey Shillito, CDIP, CPMA, CCS, CCS-P, CPEDC, COPC, breaks down the complexities of Medical Decision Making (MDM) documentation so providers can confidently capture the true complexity of their care. Attendees will learn practical, efficient strategies to ensure documentation aligns with current E/M guidelines, supports accurate coding, and reduces audit risk, all without adding to charting time.
Join Ronald Hirsch, MD, FACP, CHCQM for The PEPPER Returns – Risk and Opportunity at Your Fingertips, a practical webcast that demystifies the PEPPER and shows you how to turn complex claims data into actionable insights. Dr. Hirsch will explain how to interpret key measures, identify compliance risks, uncover missed revenue opportunities, and understand new updates in the PEPPER, all to help your organization stay ahead of audits and use this powerful data proactively.
Stay ahead of the 2026-2027 audit surge with “Top 10 Audit Targets for 2026-2027 for Hospitals & Physicians: Protect Your Revenue,” a high-impact webcast led by Michael Calahan, PA, MBA. This concise session gives hospitals and physicians clear insight into the most likely federal audit targets, such as E/M services, split/shared and critical care, observation and admissions, device credits, and Two-Midnight Rule changes, and shows how to tighten documentation, coding, and internal processes to reduce denials, recoupments, and penalties. Attendees walk away with practical best practices to protect revenue, strengthen compliance, and better prepare their teams for inevitable audits.
Happy National Doctor’s Day! Learn how to get a complimentary webcast on ‘Decoding Social Admissions’ as a token of our heartfelt appreciation! Click here to learn more →
BLOOM INTO SAVINGS! Get 25% OFF during our spring sale through March 27. Use code SPRING26 at checkout to claim this offer.
CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 1 with code CYBER25
CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 2 with code CYBER24
