Seeking some changes, AHA generally backs CMS discharge planning proposal

The AHA Jan. 4 said it “generally supports” the Centers for Medicare & Medicaid Services’ (CMS) proposed rule revising discharge planning requirements for hospitals, critical access hospitals (CAH) and home health agencies.

In comments submitted to the agency, Ashley Thompson, the AHA’s senior vice president for public policy analysis and development, said the AHA “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.”

CMS issued the proposed rule Nov. 3. The proposed discharge planning requirements would apply to hospitals (including long-term care hospitals, inpatient rehabilitation facilities and psychiatric hospitals), CAHs and home health agencies that participate in the Medicare and Medicaid programs.

The AHA urged the agency to allow flexibility in the discharge planning requirements for certain categories of outpatients. Among other recommendations, the AHA asked CMS to clarify in the final rule that compliance with the updated standards will be evaluated within the context of a hospital's or CAH’s community resources, noting that the U.S. has a shortage of mental health care providers.

Under 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, and emergency department patients whom a practitioner identifies as needing a discharge plan. Among other provisions, the rule would require the discharge planning process to take into account the patient’s goals and preferences, as well as certain quality, resource use and other measures, as required by the 2014 Improving Medicare Post-Acute Care Transformation Act.

In its call for more flexible discharge planning requirements, the AHA expressed concern that the “range of patients who would be required to have a full discharge evaluation and plan, rather than a robust set of discharge instructions, is too extensive.” For instance, the association said that “practitioners responsible for the care of observation and same-day patients receiving anesthesia or moderate sedation should be able to decide whether the patients need either full discharge evaluations and plans or comprehensive discharge instructions.”

Hospitals and CAHs’ medical staffs should indicate through their policies and procedures the appropriate levels of discharge activities and planning for each type of patient, the AHA told the agency. The final rule should allow hospitals to “tailor the discharge planning activities to the needs of each patient,” the AHA stated.

Under the proposed rule, hospitals and CAHs would need to establish a post-discharge follow-up process for patients discharged to home, although CMS does not specify the mechanism or timing of follow-up programs. Instead, the agency emphasizes the importance of ensuring that hospitals follow up “with their most vulnerable patients, including those with behavioral health conditions.”

When transferring patients, hospitals, CAHs and home health agencies would be required to provide specific medical information to the receiving facility.

The AHA said it agrees with the proposed rule’s approach of letting hospitals and CAHs decide how to best meet the needs of their patients in follow-up programs. “We welcome the opportunity to work with CMS to identify various best practices that can be incorporated into the interpretive guidance as suggestions or examples of effective programs,” the association wrote.

Click here for more on the proposed rule. Click here for more on the AHA’s letter.