CMS is Confused

The need for quality discharge planning is urgent. The Centers for Medicare and Medicaid (CMS) recently set forth enhanced discharge planning expectations for hospitals. These regulatory obligations do not assign discharge responsibilities to any defined healthcare profession. There needs to be policy reform that will assign discharge planning obligations to the nursing profession. Without clear CMS regulations on which profession should direct discharge planning, hospitals may struggle to figure out the best way to reduce readmissions, especially among drug abusers, thereby incurring financial penalties and reputational loss.

CMS Federal regulations: While policy makers have made strides in regulating discharge panning, there is room for improvement in terms of assigning a specific role for this process. There are many regulations that address how proper discharge planning can reduce readmissions: Affordable Care Act, various associations and trade groups, to name a few. But the most important federal regulation regarding discharge planning is seen in the May, 2013 revision to the Centers for Medicare and Medicaid (“CMS”) Conditions of Participation, (“CoP”) 42 C.F.R. 482.43 , “Discharge Planning”. Hospitals must follow this regulation in order to participate in Medicare and Medicaid reimbursement. Guidance to this regulation provides for specific tasks associated with planning a patient’s discharge.

The most critical element of this 2013 CMS CoP regulation is the expectation that “a registered nurse, social worker, or other appropriately qualified personnel must develop, or supervise the development of, the evaluation.” While the direction seems clear and appropriate, the downside is that there is no assigned administrator to this task. Most of the current literature on discharge planning does not discuss responsibility or accountability. Because there is no clear direction from the federal government regarding who is to be designated with this role of daily efforts on patients’ discharge planning, there appears to be finger pointing between hospital administrators if readmission rates are high because of poor discharge planning. Friction between social workers and nursing seems to be the norm which, in turn, is affecting patient care. Unless and until there is a clear federal mandate regarding responsible parties in discharging efforts, each hospital will need to implement their own structure and process content and assign primary role responsibility tone occupation: social work or nursing.

In the meantime, without CMS’ clear direction, I suggest hospitals take action now:

Assign nursing to develop, implement and oversee the discharge planning process. Otherwise, hospitals may be scrambling later to try to avoid the penalties associated with high readmission rates, especially among drug abusers, a financial risk that may be difficult to solve later.

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