Discharge Planning Conditions of Participation guidance from CMS is being seen as unhelpful.

As hospitals prepare to implement the Centers for Medicare & Medicaid Services (CMS) Discharge Planning Conditions of Participation Final Rule, they’re likely to be thrown off some by IMPACT: Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014.

Although CMS did not adopt many of its proposals in the Final Rule, released last month and effective Nov. 29, the agency could not avoid the requirements imposed by the IMPACT Act, which requires that patients be presented with data on post-acute care provider quality and resource use during discharge planning. While that might seem straightforward, it could pose problems when it comes to executing the new CMS Final Rule, since the assumption is that information to be given to the patients would be from the CMS Compare website.

According to Ronald Hirsch, MD, who described this issue during the most recent edition of Monitor Mondays, there’s an inherent problem with the utility of the information provided by CMS on the website.

“And the problem is that CMS does not provide useful information,” Hirsch told listeners. “Let’s look at skilled nursing facilities (SNFs). If I search for SNFs in my ZIP code on SNF Compare, I get a nice listing of 10 facilities, and each has a star rating for quality. If I select a single facility, it takes me an additional four clicks to get to the actual quality measures. I then get a list of … 12 factors such as rehospitalizations, flu shot percentage, and improvement in mobility. But it is just a list of the measures.”

According to Hirsch, those listings don’t provide information about actual performance in any measure.

“If I look at IRF (inpatient rehabilitation facility) Compare or LTACH (long-term acute-care hospital) Compare, I can get actual data on the respective quality measures, but you practically really need a degree in statistics to interpret it,” Hirsch said. “And of course, there are no star ratings at all, so even if I wanted to make it simple, I couldn’t.”

Hirsch is also concerned about the issue of resource use, noting that the only measure reflecting it is the spending on each episode of care (and for each provider, an episode is defined as overall Medicare spending from the day of the start of care until 30 days after discharge). Furthermore, Hirsch is concerned that CMS, in the interest of saving the Medicare Trust Fund, most likely will favor providers that spend less per episode of care – and thus, perhaps, receive better scores from CMS.

“But if I am a patient choosing a post-acute provider, do I want a provider that spends more or less on my care?” Hirsch asked rhetorically.

Hirsch is also concerned about how the information required by the IMPACT Act is presented to the patients at the time of discharge. Hirsch surmised that patients could be given a laptop so they could browse the Compare website – adding quickly that to some, that might be considered elder abuse.

EDITOR’S NOTE: An educational webcast on the subject, “Discharge Planning Conditions of Participation: The Final Rule,” by Dr. Hirsch is now available on-demand at the RACuniversity bookstore.

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