CMS Sounds the Alarm on Discharge Planning: Are You Prepared?

Navigating healthcare regulations is complex, and it’s essential for case managers to stay informed and adapt to the latest changes. In June, the Centers for Medicare & Medicaid Services (CMS) released a crucial memo titled “Requirements for Hospital Discharges to Post-Acute Care Providers.” At Strata Health, we are here to support you in navigating the latest guidelines effectively. 

Background: CMS Regulations on Discharge Planning 

Let’s start with a bit of background. CMS has long-standing regulations regarding discharge planning, primarily outlined in 42 CFR 482.43. These regulations underwent significant modifications in 2019. One of the most notable changes was the requirement for hospitals to provide information on post-acute care providers’ quality and resource use data.  Additionally, CMS expanded the requirement to offer choices during a transition of care to include long-term acute-care hospitals (LTACHs) and inpatient rehabilitation facilities (IRFs), in addition to home care and skilled nursing facilities (SNFs). The overarching principle remains that patients should always be offered choices for any provider they are being referred to. 

While CMS publishes interpretive guidelines for various sections of Conditions of Participation, it’s worth noting that guidelines for the 2019 discharge planning changes have not yet been released. This has left organizations to navigate this area without the benefit of CMS’s specific guidance. 

Key Takeaways from the CMS Memo  

Now, let’s dive into the heart of the matter—what does the CMS memo have to say, and why is it important? 

• Behavioral Issues: One of the primary concerns highlighted in the memo is the failure to inform post-acute providers about patients with behavioral issues. This omission can potentially put both patients and providers at risk, as behavioral issues may require specialized care and attention. 
• Medication Reconciliation: Poor medication reconciliation practices, especially concerning psychotropics and opioids, have been called out. Some patients were not provided with necessary prescriptions, leading to delays in obtaining essential medications. 
• Skin Issues: Hospitals were found to be omitting information about skin issues that required treatment during the hospital stay. This lack of communication left post-acute providers unaware of critical care needs, hindering effective care transitions. 
• Durable Medical Equipment (DME): The memo points out instances where hospitals failed to inform post-acute providers about the patient’s need for DME. This resulted in delays in arranging the delivery of essential equipment to the facility, impacting patient care. 
• Home Environment: Lack of communication about the patient’s home environment was another issue raised. This includes failing to inform post-acute providers if the patient is homeless or has no caregiver, crucial information for discharge planning. 
• Goals of Care and Treatment Preferences: Hospitals were found to be omitting information about the patient’s goals of care and treatment preferences. This includes critical end-of-life care preferences. Failure to convey these preferences resulted in situations where patient wishes were not honored. 

What You Can Do 

So, what should case managers and healthcare professionals do in light of this memo? 

• Stay Informed: Start by reading the full CMS memo. It provides detailed insights into these issues and is a valuable resource for understanding the new expectations. 
• Assess Your Discharge Program: Consider how your current discharge planning practices align with the issues highlighted in the memo. Are there areas that need improvement or additional attention? 
• Be Proactive: Remember that this memo was addressed to survey agencies, indicating CMS’s intent to focus their reviews on these issues. Take this as a sign to ensure your processes are in order and compliant with the new guidelines. 

Ensure Compliance and Improve Patient Care with Strata Health 

Strata Health provides you with the tools and support you need to enhance your discharge planning processes, optimize patient care, and maintain regulatory compliance. Together, we can navigate these complexities and ensure that every patient receives the best care during the transition from the hospital to post-acute care settings.  

Contact us today to learn more about how our solutions can streamline your processes and help you meet the challenges of compliance.