How does the new hospital discharge planning rule impact relationships between hospitals and skilled nursing facilities (SNFs)?
By Maria Arellano, MS, RN
Ignoring key regulatory changes in other health care provider settings is a dangerous practice. Although you may be tempted to focus only on your internal challenges with the rapid-fire changes from CMS, many of the regulatory changes that your provider partners are experiencing may indeed impact you as well. An excellent example of this is the recent CMS Final Rule on Hospital Discharge Planning Regulations.
CMS issued the Final Rule on September 26,2019 with a primary aim to further efforts to reduce rehospitalization through implementation of comprehensive discharge planning requirements that were mandated by the IMPACT Act of 2014. Effective November 29, 2019, this ruling applies to hospitals, critical access hospitals (CAHs) and home health agencies (HHAs).
The Final Rule focuses on 4 areas:
- Discharge Planning
- Coordination of care with PAC providers
- Patient Choice
Why should SNFs care about the Final Rule on Hospital Discharge Planning?
As part of the discharge planning requirements, hospital providers must assist patients in selecting a post-acute care (PAC) provider by sharing the PAC’s performance data for the providers that are consistent with their care needs and treatment goals and preferences. What story will your data tell?
If you have enjoyed a good relationship with hospital referral sources in the past solely because you’re prompt and make their job easier, you may see a change as the well-informed decision maker may bypass your facility because of your performance data.
Gone are the simple lists with local SNFs and an asterisk to indicate their preferred providers. Hospitals are now prohibited from endorsing any facility or creating “preferred provider” lists, but armed with quality measures, staffing ratios and 3-years of survey results, the patient is able decide based on performance data and not a subjective list.
CMS left it up to the hospitals to determine what quality data they share and in what format. Nursing Home Compare Five Star Data is a likely approach despite its presentation of data with time lags which fails, in many cases, to tell the whole story. Now with the controversial “red hand,” patients may not understand the range of violations included and shy away from those providers.
Interoperability is also a focus of the requirement and will place more pressure on you to be able to receive this information electronically. Are you and your EHR ready for that? [ Related: Best-in-Class Analytics + EHR = Better Together ]
The new rule also brings a positive note as it mandates a timely flow of patient care information to SNFs and may help with the information you need to be successful with the new patient driven payment model (PDPM).
What can SNF providers do in response to the New Final Rule?
- Educate your acute partners on what performance data is available and how to interpret. You know the pitfalls of many of the quality measures, don’t assume they know. Providing insight into this key data can help ensure the right data is presented to patients. Offer a lunch time learning session for discharge planners on how to interpret the quality measures. Consider creating a handout for patients on how to read the performance data.
- Tell YOUR story. Building relationships with your acute partners is a must in today’s market and that relationship must be ongoing. If the publicly reported data doesn’t adequately reflect your quality, act. Proactively provide your current performance data as well as additional measures that best reflect your quality.
- Make sure your partners know your clinical capabilities to ensure you are included as an option in the discharge planning process for all appropriate patients.
How PointRight can help
PointRight solutions offer comprehensive tools to provide insight into your clinical performance beyond the data that is publicly available. Our Performance Management products not only allow you to develop and meet your goals using industry-recognized, actionable analytics, but our solutions enable you to share your performance story and compete more effectively.
Maria Arellano, MS, RN
Senior Healthcare Specialist, PointRight
Maria has over 35 years’ experience as a registered nurse in the post-acute industry. Maria has served in a variety of roles directly in or supporting the long-term post-acute care sector including staff development, director of nursing and corporate consultant where she demonstrated regulatory excellence and exemplary quality outcomes. Previously she was a nursing home quality specialist with a quality improvement organization (QIO) and worked to enhance the quality of care for residents. Maria participated on CMS Technical Expert Panels as well as various committees and advisory boards throughout her career. She is focused on quality improvement, which fuels her passion for transforming data into knowledge and actionable insights.