CMS Rules 2019: How (And When) New Hospital Discharge Planning CoP Will Affect You

Hint: It’s later than expected, but you’ll still need to prepare

How closely related in your mind are the words “discharge planning” and “admission”? According to the Centers for Medicare and Medicaid Services (CMS), they should be closely related, if not intertwined, as you’ll find out in the latest hospital discharge planning webinar by health care consultant Toni Cesta.

Regardless of how far your practice has progressed in connecting these two ideas, you’ve surely been waiting anxiously for CMS’s promised changes to Hospital Conditions of Participation (CoPs) regarding discharge. While the waiting continues, there is groundwork to be done now to prepare.

Rewire Your Thinking about Discharge Planning

Firstly, CMS wants you to think of discharge planning as a process that starts when the patient is admitted.

Some would argue that it’s hard to make this change because of the very words used. So what would happen if you—at least internally—replaced “discharge” with “transition”?

While “discharge” carries the connotation that you’ve been relieved of responsibility to the departing patient, “transition” implies that you’re responsible for seeing the patient through the journey to either home care or a skilled nursing facility. The latter term also implies a responsibility to educate the patient on what to do after they leave the hospital, as well as to communicate with those you will be transitioning the patient to after they leave your care.

Whatever word you use, the key is a mindset shift: It’s important to see hospital discharge planning as a transition process that involves providers, interdisciplinary care team members, patients and caregivers.

Proactively Plan for November 2019

So what’s new for 2019? The short answer is: not much … yet. As you know, three years ago CMS set a goal to publish a final rule regarding discharge planning in 2018. The agency has now extended that deadline to November 3, 2019, citing the scope of public comments and the rule’s complexity.

But don’t get too comfortable with the status quo. You have another year to get your systems and proactive plans in place. But rumors have it that the final rule could mean greater expenses for your practice. The main consequence is that you might be spending a good bit of 2019 putting plans in place to handle that added expense.

For instance, word on the street is that the coming changes will include requirements that you: collect 21 data elements, document physician-directed updates, and comply with yet another CoP to standardize patient assessments across providers.

Pro Tip: In an earlier post this year, you’ll find a refresher on hospital discharge planning rules and how the CoPs interact with the Improving Medicare Post-Acute Care Transformation Act (IMPACT Act). The more knowledge you have, the more of an asset you’ll be to your practice!

Evaluate Your Current Discharge Process

As part of preparing for the new hospital discharge planning CoP, check your current practices to ensure they match with what CoPs exist now:

  • Follow the discharge planning evaluation, which includes providing the evaluation to the patient as well as the proper development and supervision of said evaluation. Evaluation must be included in patient’s medical record.
  • Ensure the discharge plan is properly developed according to the discharge evaluation.
  • Transfer the patient and patient’s medical record to appropriate post-hospital care and arrange for any necessary post-hospital services.
  • Reassess your discharge planning process on an on-going basis.

Now is not the time to sit back and wait for future rule changes. Instead, take the opportunity to ramp up your discharge planning efficiency and comply with CoPs, says case management consultant Cesta. In his AudioSolutionz webinar, “Know the CMS Discharge Planning Rules for 2019,” Cesta walks attendees through the most-up-to-date CoP requirements and presents strategies for engaging providers, interdisciplinary care team members, and patients across the continuum of the discharge planning process.

To join the conference or see a replay, order a DVD or transcript, or read more

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