CMS clarifies recent hospice, discharge assessment regulations

The Centers for Medicare & Medicaid Services recently addressed provider questions related to regulations pertaining to discharge assessments and agreements between skilled nursing and hospice providers.

In June, CMS issued a final rule regarding contract requirements for hospice providers operating within SNFs. The rule is intended to create clear definitions about which services the hospice operator will be responsible for and which the SNF will provide. The rule mandates a single contract between the skilled nursing operator and an associated hospice provider. It does not require a separate contract for each individual hospice patient, CMS officials said in an Open Door Forum call Thursday.

Surveyors are expected to begin to issue citations for noncompliance with this hospice rule “in the near future,” although a precise date has not been set, the officials said.

Last month, CMS issued a memorandum clarifying the steps skilled nursing facilities and nursing facilities must take to comply with Minimum Data Set requirements for incomplete or unsubmitted discharge assessments. Providers have until Oct. 1 to comply with the memo. Some providers have discovered that residents continue to appear on the facility roster even after a discharge assessment is completed, according to CMS’ Jemima Drake, M.P.H., R.N. This occurs for residents with multiple resident IDs. Providers that encounter this situation should contact the state RAI or automation coordinator, Drake advised.

Officials on the call could not provide an anticipated release date for the new RAI manual, which will include changes to take effect Oct. 1. However, they said CMS soon will issue a transition memorandum providing more detail about the new items.