CMS’ Discharge Planning Proposed Rule and the IMPACT on Post-Acute Care Transitions

Stephanie Jackson | | October 27, 2017

No one knows better than a case manager the importance of quality data to help facilitate a safe transition of care for our patients. Quality data includes accurate, relevant and current information about the patient AND the post-acute care entities. In September 2014, Congress passed the Improving Medicare Post-Acute Care Transformation (IMPACT) Act. At the time, patient assessment data was standardized by provider type, but not across the different post-acute care (PAC) settings. So, a skilled nursing facility, a physical rehabilitation center, and other types of PAC facilities might have completely different sets of questions they asked during patient assessments, and different ways of recording that information. The IMPACT Act, which is still in the process of being implemented today, was an effort to standardize those assessments across all PAC providers, so that case managers and others would be able to compare apples to apples and make the best care decisions for their patients.

“In essence, the act seeks to standardize data elements used through various patient and resident assessment instruments by aligning certain data elements across instruments, to support our ability to measure and compare quality across the providers and settings of care,” said Patrick Conway, MD, MSc., CMS Acting Principal Deputy Administrator, and Deputy Administrator for Innovation and Quality, and CMS Chief Medical Officer, in a 2016 video from MLN Connects published on YouTube.1 “The act allows interoperability, which permits the seamless exchange of information across providers—not only PAC providers, but other providers who offer care to individuals as well. In the ideal state, important information would follow the patient, as services are delivered in hospitals and by physicians, long-term and PAC providers, and home- and community-based service providers. This will be a critical step towards coordinating care and proving Medicare beneficiary outcomes.” 

Certainly, the goals Conway mentioned are the same goals of case managers everywhere—to have a uniform way to measure and compare PAC providers in order to make the best possible decision for each patient based on his or her individual needs. But we’ve still got a ways to go.

In October 2015, just over a year after the introduction of the IMPACT act, CMS announced the Discharge Planning Proposed Rule, which would “revise the discharge planning requirements that hospitals, including long-term care hospitals and inpatient rehabilitation facilities, critical access hospitals, and home health agencies, must meet in order to participate in the Medicare and Medicaid programs,” according to CMS’ website.2 “The proposed changes would modernize the discharge planning requirements by: bringing them into closer alignment with current practice; helping to improve patient quality of care and outcomes; and reducing avoidable complications, adverse events, and readmissions.” Importantly, CMS says, the proposed rule would also, finally, “implement the discharge planning requirements” of the IMPACT Act.

Under the proposed rule, hospitals and critical access hospitals would be required to:

  • Develop a discharge plan within 24 hours of admission or registration;
  • Provide discharge instructions to patients who are discharged home (proposed for hospitals and critical access hospitals only);
  • Have a medication reconciliation process with the goal of improving patient safety by enhancing medication management (proposed for hospitals and critical access hospitals only);
  • For patients who are transferred to another facility, send specific medical information to the receiving facility; and
  • Establish a post-discharge follow-up process (proposed for hospitals and critical access hospitals only).

With already-heavy workloads, case managers are going to need sophisticated tools in order to be ready to meet these requirements when the rule takes full effect. For example, in order to develop a discharge plan within 24 hours as the proposed changes require, case managers will need to find a way to sift through information about hundreds of different PAC providers quickly and efficiently. Luckily, software solutions exist now that allow case managers and other hospital workers to do just that—a comprehensive database with contact and geographical information, quality scores, medical and non-medical resources, and corresponding financial information for a variety of PAC providers.

Another critical feature of such a database, when it comes to meeting the requirements of the new CMS proposed rule, is that both the clinical care team and the patient and family members can access the database to make sense of the choices available. That’s because the new rule has a lot more focus on taking into account the patient’s input in their own care. “The proposed rule emphasizes the importance of the patient’s goals and preferences during the discharge planning process. These improvements should better prepare patients and their caregivers to be active partners for their anticipated health and community support needs upon discharge from the hospital or post-acute care setting,” says the CMS website. “In addition, patients and their caregivers would be better prepared to select a high-quality post-acute care provider, since hospitals, critical access hospitals, and home health agencies would be required to use and share data, including data on quality and resource use measures. This results in the meaningful involvement of patients and their caregivers in the discharge planning process.”

Case managers are committed to providing the highest quality and most complete post-acute care information to our patients. We realize the importance of patient and family buy-in of the discharge plan and its direct impact on keeping the patients from being readmitted to the hospital, and I believe that most of my colleagues support the proposed rulings in the IMPACT Act to help make this a reality. We also know, however, that it’s really difficult to access current, clean PAC data (that we trust) in an efficient manner. We need a resource database that not only provides lists, qualifications and special offerings of post-acute care providers but offers quality scores to help assure the case manager is creating the best discharge plan. We have a ways to go, but I’m confident that this type of solution will blaze a new trail for our patients and care team members.

About Carelike

Carelike's extensive database of medical and non-medical transition care providers allows your discharge team to improve their efficiencies. Provider data is augmented with proprietary professional quality metrics as well as CMS scoring. Our technology provides ease of use standalone portals or EHR integration to help discharge teams select the best care providers. 

Organize your patient and family communication with our CareTrait technology. Comply with CMS initiatives including the proposed patient discharge IMPACT Act rule and significantly reduce the burden on this already over-stretched group of professionals. The solution greatly improves communication between discharge teams, patients and families and prioritizes preferred community-based services enabling the case manager to fulfill their responsibilities while improving care coordination.