Tackle Tough Compliance Areas: Conditions of Participation, the 2-Midnight Rule, the NOTICE Act, the HINN, Changes in Patient Choice, and Much More!

A good outcome from a Joint Commission survey in 2018 is more critical than ever, especially if you want to continue receiving Medicare payments. Case managers must be constantly aware of the myriad of compliance issues that impact your daily practices. Your compliance is under scrutiny during audits by CMS and the Joint Commission, which are paying special attention to the 2-Midnight Rule, the NOTICE Act, HINNs, The Important Message, and other compliance issues.

The Centers for Medicare and Medicaid Services (CMS) requires that all Medicare inpatients receive written information about their hospital discharge appeal rights.

A-0117 (Rev. 75, Issued: 12-02-11, Effective: 12-02-11, Implementation: 12-02-11) §482.13(a)(1) A hospital must inform each patient, or when appropriate, the patient’s representative (as allowed under State law), of the patient’s rights, in advance of furnishing or discontinuing patient care whenever possible

CMS has defined how this “Important Message from Medicare” (IM) is to be delivered by hospitals to Medicare beneficiaries:

  • The IM is a standard notice that must delivered to all Medicare inpatients within two days of admission and no more than two calendar days before discharge.
  • The IM form is an Office of Management and Budget (OMB) approved form and the content cannot be altered from its original form. The OMB control number must appear on the notice.
  • The timeframe for the delivery of the form is clearly spelled out in the Conditions of Participation (CoPs) 482.13(a)(1), as illustrated in this table.
  • The IM is to be signed and dated by the beneficiary (patient or appointed representative) to acknowledge receipt.
  • The department responsible for delivering the form is determined by the hospital and is usually performed by Registration, Case Management, Social Work, or Nursing.

It is important to remember that CMS requires 100% compliance, so organizations should hardwire the process.

Important Message from Medicare: Hardwire the Process for Compliance

The first step in hardwiring the process is to create and implement policies and procedures that define how the notification process will occur during every hospital day. Instructions are included in Chapter 30 of the Medicare Claims Processing Manual.

To ensure compliance, we encourage you to review the instructions in the CMS Claims Manual regarding how and when to deliver the IM and steps to take when the beneficiary (patient or appointed representative) requests a QIO review.

Additionally, you need to audit your performance. Most hospitals audit for compliance in their monthly closed medical record review, which enables the organization to monitor the timeliness of delivery of both the IM admission and IM discharge forms.

Assessing Compliance with the IM Requirements

To assess your compliance with these requirements, your organization should consider the following questions:

  • What is your hospital’s policy for notifying Medicare beneficiaries (patients or appointed representatives) of the patients’ rights to appeal a discharge decision?
  • What is your hospital’s policy when a patient is incapacitated or has an appointed representative who must be informed of the discharge appeal rights and process?
  • Does your hospital have alternative means, when necessary, for communicating patients’ rights when English is not the beneficiaries’ primary language?
  • Do staff members know what steps to take if the beneficiary requests a QIO review?

Timeliness of IM Delivery

To ensure timeliness of IM delivery, review inpatient medical records for Medicare beneficiaries to determine whether the records contain a signed and dated IM provided within two days of the patient’s admission.

If a patient’s discharge occurs more than two days after the initial Important Message from Medicare was issued, another copy of the IM must be provided to the patient not more than two calendar days before the patient’s discharge. As described in the State Operations Manual, “In the case of short inpatient stays, however, where initial delivery of the IM is within [two] calendar days of the discharge, the second delivery of the IM is not required.”

While most hospitals have achieved compliance with delivery of the form on or before admission, many struggles with compliance in delivering the form at discharge. However, delivery of this notice must be documented per CMS requirements.

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