In September, the Centers for Medicare & Medicaid Services (CMS) unveiled a new final rule regarding discharge planning requirements for hospitals and home health providers. The new rule, industry leaders say, will likely create a much needed paradigm shift in the discharge planning process.
CMS’s discharge planning rule includes a number of changes that aim to help patients become more involved in their care transitions. Among the rule’s changes, patients and their families will now potentially have access to more detailed information enabling them to make smarter decisions about their post-acute care options.
Under the rule, for example, home health agencies are required to give patients and their caregivers data on quality measures and resource use measures to aid their care goals and treatment preferences. The same holds true for hospitals, which today regularly provide lists of post-acute care options without quality metrics.
Additionally, CMS also seeks to curtail delays that could lead to costly readmissions or poor patient outcomes. To that extent, the evaluation of a patient’s discharge needs and discharge plan must be documented in a timely manner, according to the new rule’s language.
On top of all that, the rule also requires patient evaluations to be included in the clinical record and discussed with the patient or a representative.
In general, CMS’s final rule has garnered a mostly positive reaction from health systems and home health providers.
“The new rule is a positive step forward for patients and caregivers alike,” Michael Johnson, home health practice president at Bayada Home Health Care, told Home Health Care News. “It offers additional transparency during hospital stays for patients and their families, along with evidenced-based outcomes of post-acute providers to help patients make informed decisions about the highest-quality providers for their next site of care.”
Moorestown, New Jersey-based Bayada provides home-based nursing, rehabilitative, therapeutic, hospice and assistive care services across nearly two dozen U.S. states, with additional locations in Germany, India, Ireland, New Zealand and South Korea.
A major paradigm shift
Prior to the issuing of CMS’s final rule, home health providers have long urged policymakers to create clear guidelines for discharge planning. Until recently, policymakers’ efforts had been met with delays.
For Bayada, the new rule is necessary and will help facilitate care that is crucial in terms of improving outcomes, according to Johnson.
“I believe it is needed,” Johnson said. “An effective discharge plan is the foundation for quality care at home — a more stringent, thoughtful process that better coordinates care between acute and post-acute providers will only serve to enhance outcomes for our patients.”
Currently, a significant number of patients discharged to home health services end up with lower-quality agencies, though there’s often a higher-quality provider within a short drive. That trend has persisted despite quality-of-care transparency improving through free, online tools like Home Health Compare.
Broadly, CMS’s final rule means that quality measures could become even more important for home health providers moving forward, according to Johnson.
“This is a paradigm shift for case managers, but a beneficial one for patients lacking that guidance due to current regulations,” he said. “The ability for a case manager to offer guidance on which providers offer superior quality will certainly put an additional emphasis effort on quality measures, but that should always be a focus for providers.”
The news rule is also an opportunity for home health providers to work with local hospital partners to help identify relevant quality metrics in a local market.
“Since CMS isn’t dictating which quality metrics should be used, there are many options beyond just Star Ratings,” Johnson said. “For example, a hospital can use claims data and outcomes specific to a hospital’s own population as relevant quality metrics.”
Health system support
Of course, home health aren’t the only care providers subject to CMS’s new rule. Hospitals and health systems are also trying to navigate what the new rule will mean for them.
Moving forward, Intermountain Healthcare plans to create and hand out material that will help patients’ and their families’ decide what type of care — and which provider — is right for them.
“Overall, engaging the patient in post-discharge decision making is positive,” Maria Hill, integrated care management assistant vice president at Intermountain, told HHCN. “We are creating educational material to provide to patients and families prior to discharge [that] incorporates quality performance.”
Founded in 1975, Salt Lake City-based not-for-profit Intermountain is the largest health care provider in the Intermountain West region, with 40,000 employees, 24 hospitals and 215 clinics, plus an in-house insurance division that serves about 900,000 members.
Officials at Intermountain believe the rule was needed to empower patients. The rule will support increased awareness and enhancement for patients and families, they say.
Jefferson Health officials likewise believe that the additional discharge planning steps from CMS will lead to a more informed patient.
Philadelphia-based Jefferson Health is a care network that includes 14 hospital locations, 7 urgent care centers, 22 rehab specialty services and 19 outpatient centers throughout Pennsylvania and New Jersey.
The health system’s current discharge planning begins relatively early in the care transition process, according to Patrice Miller, enterprise vice president of care management at Jefferson.
“Patients are assessed for their discharge planning needs and they are offered the choice of a relevant list of facilities or agencies to select if post-acute care services are required,” she said. “We work with the patient and family to meet their post-hospital care needs. A discharge plan is finalized prior to the patient leaving the hospital, and we then communicate the care plan to the next provider of care.”
Intermountain is teaming up with post-acute care providers, such as home health agencies, to fulfill CMS’s new mandate.
“We provide standardized documentation when referring and are partnering with facilities and agencies at the next level of care to meet these requirements,” Hill said.
Meanwhile, Jefferson is preparing for any additional training and support its team will need in order to comply with CMS.
“Initially, there will need to be time invested in additional training for staff and the creation of appropriate documentation that includes the post-acute care facilities and home health agencies’ relevant quality data,” Miller said.