New Discharge Rules Come with Steep Pricetag for Home Health

Home health care agencies might soon be hit hard by new discharge planning requirements, implementation of which is estimated to ring in at an annual cost of $283 million. Agencies should be required to communicate more information to other providers and more actively engage patients and caregivers in the discharge process, according to the massive proposed rule from the Centers for Medicare & Medicaid Services (CMS).

Issued Thursday, the proposed rule would revise discharge planning requirements that HHAs and other providers must meet to participate in Medicare and Medicaid. It also would implement certain provisions called for by the Improving Medicare Post-Acute Care Transformation (IMPACT) Act.

IMPACT was signed into law in October 2014, and is meant to pave the way for post-acute care payment reform by standardizing quality measurements across different provider types.


To that end, CMS proposes to withdraw previously submitted requirements for HHA discharge summaries and replace those requirements with a new standard. Under the newly proposed rule, when an HHA discharges a patient to another health care setting, it would have to share a host of data points, including:

  • Patient demographic information
  • Advance directive, if applicable
  • Lab and diagnostic test results
  • Functional status assessments
  • Social supports
  • Patient goals and treatment preferences
  • Recommendations or instructions for ongoing treatment

Other requirements would be ongoing reevaluation of patients to identify changes that would affect the discharge plan; ongoing involvement of the physician responsible for the home health plan of care; and consideration of the availability of caregivers/support persons for patients.

Home health agencies should also play a significant role in helping patients evaluate their choices of other post-acute providers. This might mean sharing data on quality measures and resource use measures and being available to answer patient and caregiver questions.


The proposed rule also lays out requirements for hospitals. They would be required to share medical information when discharging to another provider.

CMS plans to publish the proposed rule in the Nov. 3 edition of the Federal Register. It is accepting comments for 60 days.

Written by Tim Mullaney

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