What you need to know: CMS made changes to the §483.15-Admission, Transfer, and Discharge guidance.
- There were no Phase 3 requirements for this section, but CMS provided clarification about specific tags in response to feedback and questions from nursing home stakeholders.
- CMS added language that addresses against medical advice discharges for all three citations.
F622-Transfer and Discharge Requirements: Clarifies language:
- for situations involving discharge from short term rehabilitation;
- for when Medicare coverage ends but the resident still needs long term care;
- about assisting residents to apply for Medicaid;
- on how to explain denials;
- on emergent transfers to acute care; and
- around permitting return to the nursing home.
F623-Notice Requirements Before Transfer/Discharge: Clarifies the components the transfer or discharge notice should contain.
- A new notice would be required if a change in destination occurs if the original reason for discharge has changed.
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An example was added for Change of Notice.
F626-Permitting Residents to Return to Facility: Clarifies that the requirement to permit residents to return after hospitalization or therapeutic leave applies to all residents regardless of payment source.
- Language was added to help surveyors investigate situations when a facility does not permit a resident return.
- A new deficiency categorization example was added to show the harm that could occur if a facility does not permit a resident to return after a hospitalization.
Action for facilities:
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Create a template document for use in the in the medical record
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Develop an internal template order/documentation form that physicians can sign whenever a person is discharged or transferred.
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Use this AHCA tool for a list of what to include in the medical record and in an order form to comply with the requirements.
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Meet with your medical director to review the new requirement and customize the template order/documentation form (Note: You cannot customize by deleting or omitting any required information or steps).
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Have your medical director reach out to the attending physicians so they are aware of the new requirements.
Remember: Survey enforcement for the standards will begin on October 24, 2022.
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