Home Health & Hospice Week

Here’s how the summaries requirement and QAPI overlap.

July 13 is rushing toward you — will you be ready with timely discharge and transfer summaries as required by the new Conditions of Participation? Home health agencies will have their work cut out for them complying with the new mandates, industry veterans warn. And the consequences are likely to be steep for violations.

“This requirement is part of patient rights,” stresses Arlene Maxim of A.D. Maxim Consulting in Troy, Mich. “Therefore, one would expect hefty sanctions if noncompliance is found.”

Consider this preparation advice from the experts to maximize compliance and minimize your exposure to survey citations and their consequences:

1. Educate internally. First, read up on the new requirements so you thoroughly understand them. When the Interpretive Guidelines for surveyors come out, read them ASAP. Lacking the guidelines “is very unfortunate for the industry since we have such limited time to prepare,” Maxim notes — less than six months.

2. Analyze your current P&P. Take a hard look at your current policies and operations for transfers and discharges and perform a gap analysis, Maxim counsels. “Look at what is going on in the agency now in regard to how information is being communicated to the agency from the patient/representative,” she says. Determine where you are now versus where you want to be under CoP compliance.

3. Write your policy. Maxim recommends forming a discharge/transfer planning focus group to formulate a policy that will lead to a seamless transition process for discharge and transfer patients.

Deciding what will be contained in the summaries should be part of this task (for ideas, see stories, p. 35, 36). CMS eventually will tell you exactly what must go into the summaries, so keep an eye out for that update. Formalize the process in written policy.

4. Designate responsibility. Once the process is nailed down, “assign specific staff members to complete this task,” offers consultant Pam Warmack with Clinic Connections in Ruston, La. Hold staff accountable to the timelines.

Your staff will need thorough training on their duties under this policy, and why they are so important. “It will require a great deal of staff education to ensure the documents ... are completed ASAP so that they may be forwarded to the appropriate medical professional within the time frames,” Warmack cautions.

5. Educate externally. Keeping accurate track of transfers will be key for compliance with the two-day timeline. “It will be important that agencies stay in close touch with their patients and provide training for the patient and representative related to notification when a transfer takes places,” Maxim advises.

6. Look to technology. This is one area where technology may be able to greatly assist you. “Investigate software capabilities to assist in the creation of the documents,” Warmack advises.

Tech can help your communication time once documents are created as well. “I think providers may look to electronic documentation with physician portals to accomplish this task in a timely manner,” Warmack predicts.

Also check with your electronic medical records software vendor to see if they can assist you with tracking the dates for this requirement, Maxim advises. If you opt to track the discharge and transfer summaries manually, “design a notification/tracking for all discharges and transfers to assure compliance,” she urges.

7. Remember the reason. Rushing to comply with the new CoPs may feel unfair, but remember why these new requirements are in place — to help ensure patients’ well-being and safety. Limited information at the patients’ new transfer location, particularly regarding medications, “is of great risk to every patient transferred,” Maxim stresses. “Not having information can cause undue harm to the patient.”

“Communication at transition time points is a key focus” of the CoPs, notes Judy Adams with Adams Home Care Consulting in Durham, N.C. “There is a real need for coordination of care on transfer and discharge to reduce the number of potentially avoidable complications and ensure the patient receives the most consistent care and the best outcomes.”

8. Use QAPI. Which topics you target under the new Quality Assessment Performance Improvement CoP are up to you, as long as they are “focused on indicators related to improved health outcomes, patient safety, and quality of care; focused on high risk, high volume, or problem-prone areas; and that the number and scope of distinct improvement projects conducted annually be reflective of the scope, complexity, and past performance of the HHA’s services and operations,” the Centers for Medicare & Medicaid Services says in the CoPs final rule. Make the transfer/discharge summary requirement “a component of the new QAPI plan under the heading of Coordination of Care Activities,” Warmack urges.