Home Health & Hospice Week

Warning: Surveyors will be reviewing your cases discharged for cause.

While home health agencies have some serious work to do to comply with the Transfer and Discharge standard under the new Patient Rights CoP, at least Medicare didn’t pile on even more.

The Centers for Medicare & Medicaid Services did turn down some commenters’ requests related to discharges, including a mandatory 30-day notice, and a statement on the discharge notice including the address and telephone number of any agency/program that can represent the patient at a hearing.

“We do not believe a thirty day notice of transfer or discharge is a practical requirement for HHAs at this time,” CMS says in the Conditions of Participation final rule. “HHA discharges can occur in much shorter timeframes for a variety of unavoidable reasons ranging from a patient’s decision to transfer to another HHA to a patient’s transfer to an acute care provider to a situation in which HHA personnel are unable to deliver care due to an unsafe home environment.”

And CMS fended off suggestions to narrow agencies’ ability to determine their own discharge for cause policies. Some commenters claimed agencies could use the policies to “dump” difficult or

expensive patients.

Surveyors will be keeping an eye on this potential threat by reviewing records for patients discharged for cause, CMS promises in the rule. “This type of monitoring may mitigate potential negative behaviors in an HHA,” the agency hopes.

Red flag: In other words, expect special scrutiny of these patients, and an increased focus if you have an atypically large number of patients discharged under this policy, experts warn.