The Centers for Medicare & Medicaid Services (CMS) is testing revised surveyor worksheets that could affect the way hospitals are scored on compliance with the Conditions of Participation (CoPs) for discharge planning.
The worksheets include new questions designed to help hospitals better assess their discharge-planning process with an emphasis on three themes that highlight the importance and need for technology to streamline communication and capture data to help achieve better outcomes.
1. Pre-Admission Level of Care
CMS has added questions about whether hospitals get documentation about a patient’s preceding level of care. This is important because this documentation can help ensure the patient’s medical needs match his placement.
As an example, if a patient is admitted from a skilled nursing facility the surveyor will look at whether the patient’s prior setting has the capability to provide necessary post-acute services to that patient. If not, hospital staff should take the necessary steps to ensure the patient is safely placed to a facility that can care for him.
2. Post-Acute Provider Collaboration
One of the new survey questions asks, “Does the hospital have a process for collecting and considering feedback from post‐acute providers in the community about the effectiveness of the hospital’s discharge-planning process?”
Hospitals may assume their relationship with post-acute providers is good, but CMS wants to ensure the post-acute provider has been given an opportunity to have a voice in improving patient transitions.
CMS also added questions about hospitals’ follow-up after discharge, like appointment scheduling, prescription fulfillment and transportation. Without establishing secure, online communication with post-acute providers, hospitals can’t easily answer these questions.
(Note: Two examples of hospitals collecting and quantifying feedback are Overlake Hospital Medical Center in Bellevue, Wash., which distributes a survey to its providers, and Cooley Dickinson Hospital in Northampton, Mass., which regularly meets with its providers.)
3. Readmission Trends
Another new survey question asks, “Is there any evidence the patient has been readmitted to this hospital within 30 days of a prior related admission?” If the answer is “yes,” the goal is to identify and address the cause of it in order to avoid another readmission.
Additionally, if and when CMS adds readmission requirements to practice patterns, rather than just to value-based-payment patterns, hospitals will need to know their own scorecard for readmissions, the index admission and what happened in the intervening period.
(Note: Reviewing trend data (see pages 18-21) by placement type, provider, physician and diagnosis helps hospitals identify root causes of readmissions.)
Next Steps for Revised Worksheets.
State survey agency staff and hospitals that are reviewed can provide feedback to CMS on the revised worksheets through the end of September. When finalized, the new worksheets will become part of the interpretive guidelines, the foundation of the CMS federal hospital survey process, as early as October but more likely in 2013. Since CMS surveyors can conduct an accreditation survey at any time, it makes sense for hospitals to prepare now for these revised questions.
Interpretive guidelines let hospitals know what surveyors will be looking for and provide guidance about how their internal processes should be working. Staying fully informed about changes to these guidelines that measure compliance with CoPs is critical to keeping your hospital or health system in compliance.
Jackie Birmingham, RN, MS, is vice president, emeritus, of clinical leadership at Curaspan Health Group.
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