Home Health & Hospice Week

Stay tuned for separate rule on discharge/transfer summary content.

Not sure what should go into your patients’ new discharge and transfer summaries required by the new Conditions of Participation this summer? For the time being, you get to make the call.

In its October 2014 proposed CoPs rule, the Centers for Medicare & Medicaid Services proposed a list of items required in the summaries. But in the final rule released this month, CMS rescinded those requirements.

Why? Congress signed the IMPACT Act into law three days after CMS proposed the CoPs, and then CMS issued a rule specifically addressing care transitions in November 2015 (see Eli’s HCW, Vol. XXIV, No. 39). “In order to meet the require ments of the IMPACTAct for HHAs, we have decided to withdraw our proposals related to the content of the discharge summary,” and instead defer to the requirements proposed in the 2015 proposed rule, CMS says in the CoPs final rule.

The difference: In the CoPs proposed rule, CMS listed 10 items required in the summaries. In the IMPACTAct proposed rule, CMS listed 22 items (see box, this page).

So stay tuned for that final rule. “I fear there will be additional challenges when we receive the required content outline,” says consultant Pam Warmack with Clinic Connections in Ruston, La. “It may prove difficult to collect some of the required data as quickly as is needed. Consider holidays and weekends and weeks when there are multiple discharges,” Warmack tells Eli.