AMDA Comments on CMS Discharge Planning Proposed Rule

On November 3, 2015, the Centers for Medicare & Medicaid Services (CMS), published in the Federal Register (80 Fed. Reg. 68126), proposed revisions to requirements for discharge planning for hospitals, Critical Access Hospitals (CAHs), and Home Health Agencies (HHAs). The proposed rule is designed to reduce avoidable hospital readmissions and improve patient care with a focus on improvements for psychiatric and behavioral health patients, including those with substance abuse disorders. It calls for coordination, consultation, and use of information from community-based service providers as recognized by the Improving Medicare Post-Acute Care Transformation Act of 2014. The proposed rule fits within the framework of existing discharge planning regulations which are found at 42 CFR §482.43, applicable to all inpatients.

In comments to CMS, AMDA noted and applauded their recognition of AMDA’s universal transfer form as an example of document that could help prevent errors during transitions. “Overall, we believe these proposals are an important step to recognizing that transitions from the hospital to home and post-acute and long-term care (PALTC) settings present increased risk to patients that need to be recognized and accounted for in the discharge planning process. As these policies move forward, in addition to these comment periods, we urge CMS to collaborate with stakeholders in all sectors of health care in order to create a truly integrated patient-centered health care system that is all too fragmented today. We agree that a collaborative Quality Assessment and Performance Improvement (QAPI) process is appropriate to truly move forward with such a system,” stated AMDA.

AMDA also noted that “poor communication during transitions can lead to confusion about the patient’s condition and inappropriate care, duplicative tests, inconsistent patient monitoring, medication errors, and lack of follow-through with the next care setting. Navigating this system is a challenge for the patient population that enters the PALTC setting given the increased medical acuity and mental health issues and dementia often present in our population.”

AMDA was pleased to see CMS focus on health information technology (HIT) as a solution to care transitions and urged CMS to focus on patient and family needs in building a truly interoperable health care system rather than focusing on specific “check-box” type report which can be difficult in the PALTC setting.

To read AMDA’s letter click here.