Are you Paying Attention to Resident Discharge? CMS & OIG Are
In 2017, CMS put into effect the final rule that focused on discharge planning for residents from the nursing home setting. From monitoring deficiencies data, we know some facilities still do not follow current guidelines. What has become important when it comes to discharges?
Discharge Planning Starts at Admission
The discharge planning process is initiated on admission to the nursing home and requires a team effort involving the resident, representative, health care professionals and community supports. The MDS Assessment is a central part of the discharge planning process. Proper discharge planning prevents readmissions, which has been a Value Based Purchasing measure since FY 2016 and should be a priority for all skilled nursing facilities.
The focus of OIG and CMS are to assist the resident to transition to an alternate living arrangement such as home, assisted living or another nursing home and prevent post discharge complications or possible re-admission to the hospital.
Per guidelines, there are only 6 reasons to discharge of a resident from a nursing home:
- Resident’s welfare and the resident’s needs cannot be met in the facility
- Resident’s health has improved sufficiently so the resident no longer needs the services provided by the facility
- Safety of individuals in the facility is endangered due to the clinical or behavioral status of the resident
- Health of individuals in the facility would otherwise be endangered
- Resident has failed after reasonable and appropriate notice, to pay
- Facility ceases to operate
The OIG has investigated facility-initiated discharges that do not comply with these regulations. Discharges without appropriate planning can lead to an unsafe and traumatic experience for the resident. The facility could also suffer negative impacts from readmissions when the discharge is not appropriately planned.
OIG Discharge Recommendations
The OIG Report published in November 2021 determined that facility-initiated discharges in nursing homes require further investigation to fully understand factors and outcomes. In addition, the OIG has provided training and enforcement recommendations that CMS has agreed to implement. Facilities should be aware of best practice guidelines to ensure they are planning discharges appropriately.
Nursing homes can strengthen their discharge process by:
- Involving resident/representatives in discharge plan development to identify individual needs and goals
- Ensuring discharge planning process follows regulatory compliance
- Involving the IDT in ongoing review of the resident’s discharge plan and revising the plan as needed
- Using the MDS Assessment to identify areas of concern and incorporate these into discharge planning
References
OIG, Facility-Initiated Discharges in Nursing Homes Require Further Attention. https://oig.hhs.gov/oei/reports/OEI-01-18-00250.asp