NAHC Final Comments Submitted on Revisions to the Discharge Planning Requirements
January 12, 2016 04:04 PM
The National Association for Home Care & Hospice (NAHC) has submitted final comments on the proposed rule for the Revisions to Requirements for Discharge Planning for Hospitals, Critical Access Hospitals, and Home Health Agencies.
The proposed rule was issued, for the most part, to implement the discharge planning requirements in the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act). The Act requires the Centers for Medicare & Medicaid Services (CMS) to modify the conditions of participation (CoPs) and subsequent interpretive guidance to require providers to take into account quality, resource use, and other measures in the discharge planning process. CMS proposes specific requirements for the discharge planning process and extensive elements for a discharge/transfer summary.
NAHC supports CMS’ aim to improve care transitions through an effective discharge plan for all home health patients. However, there are serious concerns regarding the burden the proposed rule will have on home health agencies (HHAs), specifically as it relates to the discharge/transfer summary requirements. In addition, the current proposal contains vague standards that can lead to conflict between CMS and providers. NAHC urged CMS to provide clear guidance and flexibility for compliance.
Further, CMS is proposing a Medicare HHA CoP on discharge planning that has significantly more requirements than the current discharge planning requirements. NAHC recommended that HHAs be given 12 months following the issuance of any final rule to achieve compliance.
The proposed rule will be costly to HHAs. The requirements are estimated to increase HHA costs by $283 million annually at a time when HHA payment rates are subject to significant reductions through rebasing, productivity adjustments, and case mix weight change adjustments that in 2016 alone will reduce base rates by approximately 4.3%. If the proposed discharge planning responsibilities are to be properly implemented and managed by HHAs while maintaining care access, Medicare payment rates must be increased by an amount equal to the estimated costs, 1.57%.
A notable omission in the proposed rules is consideration of patients who have elected hospice. These rules should fully recognize and respect a patient’s choice of hospice care throughout the rule design as a patient’s election of hospice can occur prior to or during care at a hospital, SNF, IRF, LTACH, or HHA. This would include requiring hospitals to provide a list of available hospices to patients in the discharge planning process as well all the other elements of discharge planning at all other care settings.
To view NAHC’s final comments, please click here.