LTC Discharge and Transfer Requirements. Revised October 24, 2017

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LTC Discharge and Transfer Requirements Revised October 24, 2017

OUTLINE Transitions of Care LTC Discharge and Transfer Documentation Requirements Intent of the Regulations

TRANSITIONS OF CARE Understanding the Breakdowns and Impact of Ineffective Care Transitions

TRANSITIONS OF CARE Transitions of care refer to the movement of patients between health care practitioners, settings, and home as their condition and care needs change. For example, a patient might receive care from a primary care physician or specialist in an outpatient setting, then transition to a hospital physician and nursing team during an inpatient admission before moving on to yet another care team at a skilled nursing facility. Finally, the patient might return home, where he or she may receive care from a visiting nurse or support from a family member or friend. However, these transitions are often complicated and result in negative outcomes for patients.

TRANSITIONS OF CARE Breakdowns in Transitions of Care Communication Breakdowns. Care providers do not effectively or completely communicate important information among themselves, to the patient, or to those taking care of the patient at home in a timely fashion. The communication method whether verbal, recorded, or written is ineffective. Expectations differ between senders and receivers of patients in transition Culture does not promote successful hand-off (e.g., lack of teamwork and respect) Inadequate amount of time provided for successful hand-off Lack of standardized procedures in conducting successful hand-off, (e.g. use of SBAR)

TRANSITIONS OF CARE Breakdowns in Transitions of Care Patient Education Breakdowns. Patients or family/friend caregivers sometimes receive conflicting recommendations, confusing medication regimens, and unclear instructions about follow-up care. Patients and caregivers are sometimes excluded from the planning related to the transition process. Patients may lack a sufficient understanding of the medical condition or the plan or care. As a result, they do not buy into the importance of following the care plan, or lack the knowledge or skills to do so.

TRANSITIONS OF CARE Breakdowns in Transitions of Care Accountability Breakdowns. In many cases, there is no physician or clinical entity that takes responsibility to assure that the patient s health care is coordinated across various settings and among different providers. Providers especially when multiple specialists are involved often fail to coordinate care or communicate effectively, which creates confusion for the patient and those responsible for transitioning the care of the patient to the next setting or provider. Primary care providers are sometimes not identified by name, and there is limited discharge planning and risk assessment. Steps are not taken to assure that sufficient knowledge and resources will be available either at home or at the next setting to the patient upon discharge.

TRANSITIONS OF CARE Prevalence of Adverse Events 22% of Medicare Beneficiaries Experienced Adverse Events During a Post- Hospitalization SNF Stay in 2011 11% of Medicare Beneficiaries Experienced a Temporary Harm Event During a Post-Hospitalization SNF Stay in 2011 60% of These Events Were Likely Preventable

TRANSITIONS OF CARE The Cost to Medicare $28.4 Billion Total Medicare Payments Paid to SNFs in 2011 for Services Provided to 1.8 million beneficiaries $4.4 Billion Yearly Cost of Adverse Events to the Medicare Program 15% of Medicare Costs are Associated with Adverse Events

TRANSITIONS OF CARE Elements Recommended by The Joint Commission to Improve Care Transitions: Multidisciplinary Communication, Collaboration and Coordination from Admission through Transfer Including Patient/Family Education Clinician Involvement and Shared Accountability During Transition Comprehensive Care Planning and Risk Assessment Including Medication Reconciliation Standardized Transition Plans, Procedures and Forms Standardized Training for Clinical Staff Timely Follow-Up, Support and Coordination Post-Transition Root Cause Analysis When a Readmission Occurs Evaluation Compliance with Transition Process

DISCHARGE/TRANSFER DOCUMENTATION REQUIREMENTS 42 CFR 483.15.(c)(2)

DISCHARGE/TRANSFER DOCUMENTATION REQUIREMENTS When the facility transfers or discharges a resident under any permitted circumstance, the facility must ensure that the transfer or discharge is documented in the resident s medical record and appropriate information is communicated to the receiving health care institution or provider. Documentation in the resident s medical record must include the basis for the transfer/discharge: Documentation by the attending physician if the resident s health status has improved or the resident is a danger to self Documentation by an affiliated physician if the resident is a danger to others If applicable The specific resident need(s) that cannot be met, facility attempts to meet the resident needs, and the service available at the receiving facility to meet the need(s)

DISCHARGE/TRANSFER DOCUMENTATION REQUIREMENTS Information provided to the receiving provider must include a minimum of the following: Contact information of the practitioner responsible for the care of the resident. Resident representative information including contact information, if applicable. Advance Directive information. All special instructions or precautions for ongoing care, as appropriate. Comprehensive care plan goals. All other necessary information, including a copy of the resident s discharge summary (if return is not anticipated), and any other documentation, as applicable, to ensure a safe and effective transition of care.

DISCHARGE/TRANSFER DOCUMENTATION REQUIREMENTS Special Instructions may include: Treatments and devices (oxygen, implants, IVs, tubes/catheters) Precautions such as isolation or contact Special risks such as risk for falls, elopement, bleeding, or pressure injury and/or aspiration precautions Other Necessary Information may include: Resident status, including baseline and current mental, behavioral, and functional status Reason for transfer Recent vital signs Diagnoses and allergies Medications (including when last received) Most recent relevant labs, other diagnostic tests, and recent immunizations

DISCHARGE/TRANSFER DOCUMENTATION REQUIREMENTS When return is not anticipated, the Discharge Summary must include: The resident s disease diagnoses and health conditions Course of illness/treatment or therapy Medications Pertinent lab, radiology, consultation results Instructions or precautions for ongoing care

INTENT OF THE REGULATIONS Surveyor Guidance

INTENT OF THE REGULATIONS Facilities may choose their own method of communicating transfer or discharge information, such as a universal transfer form or an electronic health record summary, as long as the method contains the required elements. The transferring or discharging facility may transmit the information electronically in a secure manner which protects the resident s privacy, as long as the receiving facility has the capacity to receive and use the information. Communication of this required information should occur as close as possible to the time of transfer or discharge.

INTENT OF THE REGULATIONS

QUESTIONS? PPennington@compliagent.com