gbryant100EDITOR’S NOTE: Gloryanne Bryant, RHIA, CCS, CCDS, will be conducting a webinar at 1:30 p.m. EST on Thursday, July 21, 2011 to advise providers on the pitfalls and bottom-line consequences of the post-acute care transfer rule.


We often refer to the post-acute care transfer rule (PACT) as the discharge disposition rule. Patient status or disposition is an approved issue for several RACs under the permanent program. Understanding the bottom-line ramifications of the Centers for Medicare & Medicaid Services’ (CMS) post-acute transfer policy is challenging for many hospitals.


The PACT transfer payment policy was based on the CMS belief that it was inappropriate to pay a sending (transferring) hospital a full MS-DRG payment for less than a full course of treatment. When the transfer payment policy initially was enacted by Congress and implemented by CMS, the scope was relatively narrow, but as time passed the scope has expanded. Today, nearly one-third of all MS-DRGs have the potential to be impacted by the PACT rule criteria.


Some hospitals have status code and/or discharge level assigned or selected by staff other than HIM inpatient coding staff; even if this is the case, inpatient coders still should validate accuracy and make corrections once they have reviewed the medical record during the coding process. A good resource is the February 2008 MedLearn Matters publication on this topic.


Table 5 of the Inpatient Prospective Payment System (IPPS) lists all of the PACT and special-pay DRGs. This table also lists titles, relative weights and geometric lengths of stay for all DRGs. Distribution of this table to coding staff members as well as discharge planners and utilization managers can help make them all well aware of how documentation and coding may or may not trigger the PACT rule.


The Common Working File (CWF), which includes all claims data and activity for any given patient, allows RACs to perform automated reviews of the post-acute care transfer policy and easily mine data for errors. This major data file shows when patients start and stop receiving certain services, and it also provides insight into when patients move from one level of care to another.


Providers should be auditing and examining validation of patient status, making sure to have proactive processes in place (whether internally monitored or using external vendor resources). A best practice is to be proactive rather than reactive.


About the Author


Gloryanne Bryant, RHIA, CCS, CCDS, is the regional managing director of HIM for Kaiser’s 21 acute-care hospitals in northern California. She co-chairs the regional RAC committee with compliance.


Contact the Author


To comment on this article please go to


RACs Collect $233.4 Million in Overpayments During Third Quarter of FY 2011

Share This Article