Skilled nursing facilities must complete a discharge assessment when a resident is transferred from a certified to a non-certified bed, even if both beds are in the same building, the Centers for Medicare & Medicaid Services emphasizes in a recent memorandum.

Federal regulations define transfer and discharge as when a resident moves from a Medicare- or Medicaid-certified bed to a non-certified bed, “whether that bed is in the same physical plant or not,” according to a memo sent Monday to state survey agency directors. Minimum Data Set 3.0 Discharge Assessments are called for whenever this type of bed transition occurs.

CMS sent the memo as a way of “reinforcing the requirement,” the document states. It notes that nursing facilities and skilled nursing facilities that do not submit these required assessments could face survey citations.

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