CMS Issues New Interpretative Guidelines for Hospital CoP’s for Discharge Planning: Obligation to Provide Discharge Planning Evaluation

CMS Issues New Interpretative Guidelines  

for Hospital CoP’s for Discharge Planning:

Obligation to Provide Discharge Planning Evaluation
On May 17, 2013, the Centers for Medicare and Medicaid Services (CMS) issued revisions to the State Operations Manual (SOM), Hospital Appendix A – Interpretative Guidelines for 42 CFR 482.43, Discharge Planning.  This is the third in a series of articles about these interpretative guidelines.


42 CFR Section 482.43(b) Standard: Discharge Planning Evaluation states: “(1) The hospital must provide a discharge planning evaluation to the patients identified in paragraph (a) of this section, and to other patients upon the patient’s request, the request of a person acting on the patient’s behalf, or the request of the physicians.”


Interpretative guidelines related to this Section provide as follows:


For every inpatient identified under the process required at Section 482.43(a) as at potential risk of adverse health consequences without a discharge plan, a discharge planning evaluation must be completed by the hospital.  In addition, an evaluation must also be completed if the patient, or the patient’s representative, or the patient’s attending physician requests one.  Unless the hospital has adopted a voluntary policy of developing an evaluation for every inpatient, the hospital must also have a process for making patients, including the patient’s representative, and attending physicians aware that they may request a discharge planning evaluation, and that the hospital will perform an evaluation upon request.  Hospitals must perform the evaluation upon request, regardless of whether the patient meets the hospital’s screening criteria for an evaluation.

In contrast to the screening process, the evaluation entails a more detailed review of the individual patient’s post-discharge needs, in order to identify the specific areas that must be addressed in the discharge plan.


First, it is important to note that the requirement to provide discharge planning evaluations applies only to inpatients; it is inapplicable to patients in emergency rooms or who are seen on an outpatient basis.


According to CMS, the Interpretative Guidelines mean that hospitals must:

  • Show evidence of discharge planning evaluation activities in every unit that includes inpatient beds.
  • Comply with the hospital’s policies and procedures related to discharge planning evaluations.
  • Notify patients, their representatives and physicians they may request discharge planning evaluations and that the hospital will conduct an evaluation upon request, if the hospital does not require a discharge planning evaluation for all inpatients.
  • Ensure that discharge planning and unit nursing staff can describe the process for patients or their representatives to request discharge planning evaluations.
  • Demonstrate that patients and their representatives are aware that they can request discharge planning evaluations.
  • Show that physicians are aware that they can request discharge planning evaluations or that the hospital informs the medical staff that they can request them.


New Interpretative Guidelines make it clear that CMS is committed to beefing up discharge planning activities in hospitals.  Hospitals may be required to provide additional resources in order to comply with CoP’s as evidenced by the Interpretative Guidelines.


©2013 Elizabeth E. Hogue, Esq.  All rights reserved.

Elizabeth E. Hogue, Esq.

Office: 877-871-4062

Fax: 877-871-9739


Twitter: @HogueHomeCare


No portion of this material may be reproduced in any form without the advance written permission of the author.

March 2013 IV Lines

Congressman Kevin Yoder Visits Alternacare

Wednesday, January 30, 2013 Alternacare Infusion Pharmacy was honored by the visit of Congressman Kevin Yoder.  Mr. Yoder met with owners Mike Hayden and Rick Lane regarding the services that Alternacare provides for thousands of local area residents with infectious diseases, immune deficiencies, cancer, short bowel syndrome, cystic fibrosis and other conditions to receive the care they need in the comfort of their own homes.  The Congressman toured the facility and spoke with Alternacare’s pharmacists to learn about the intake process, insurance benefit verification, preparation of medications and delivery staging process.  During the visit, he was able to see the sterile preparation room, warehouse and infusion suites.   Our nurse Sarah shared with Mr. Yoder the importance of patients being able to be cared for in their own home rather than having to stay in a facility to receive intravenous medication or having to make daily visits to a clinic or office to receive medication.  There was also discussion regarding the lack of benefit coverage that a Medicare recipient has for home infusion.  As the picture denotes, Medicare only covers the actual medication.  Medicare does not cover the necessary pumps, supplies and services required to administer the medication.  This lack of coverage creates high out-of-pocket costs for Medicare patients, causing the patient to elect to make regular visits to a facility to receive their medication, to stay in a skilled nursing facility or to have to change to an oral medication, which may not be as effective as the intravenous route of administration.  Many patients in this population would greatly benefit from the home infusion alternative when the therapy is administered in the comfort and convenience of the patient’s own home.  An additional important factor is the cost savings for taxpayers if Medicare covers home infusion.  Currently, two bills (Senate and House) are being scheduled to be re-introduced in late spring or early summer. These bills would address the appropriate changes necessary for this patient population to have the health benefit coverage needed when a physician prescribes home infusion therapy.

To learn more about this legislation, please visit With the potential support of future Medicare Home Infusion Legislation by Congressman Kevin Yoder and other Congressmen and Senators, more innovative healthcare solutions will be available to the Medicare population.  We thank Congressman Kevin Yoder for taking the time to visit Alternacare on this cold, blustery day in January.

Drug Shortages

Drug shortages have always been something that pharmacies have had to deal with over the years, however, we usually found that allocation from manufacturers would get you through the tough times.  Last year, 2012, proved to be much more difficult.  The home infusion industry is a small component of a much larger healthcare industry that has felt the pain of drug shortages and we may continue to feel it in 2013.

According to an article from the New York Times published November 16th, 2012:

Rationing is just one example of the extraordinary lengths being taken to address the shortage, which health care workers say has ceased to be a temporary emergency and is now a fact of life. In desperation, they are resorting to treating patients with less effective alternative medicines and using expired drugs. The Cleveland Clinic has hired a pharmacist whose only job is to track down hard-to-find drugs. (see link below).

Fortunately, Alternacare has some great buyers that continue to find resourceful ways to acquire the medications when they are in short supply.  Many times we can work in conjunction with the physician to see if there is a clinically equivalent substitute or a way to share supply with area hospitals.

Noted below are two websites for reference regarding medications that are in short supply.  One is the Food and Drug Administrations website and the other is on the American Society of Hospital Pharmacists website.



As always, we will continue to focus on patient quality and service, while doing our very best to access the medications that every patient needs.

Recipe for St. Patrick’s Day Blondies











2/3 cup butter

1-1/4 cup brown sugar, packed

1 egg

1 tsp vanilla extract

2 cups flour

1/2 tsp baking soda

1 cup green M&M’s

Preheat the oven to 350 degrees. Spray non stick spray in a 13×9 inch glass dish.  In a small bowl combine the flour, egg, baking soda.  Mix the butter and sugar together with a hand mixer or stand mixer. Add in the egg, mix well. Then add in the vanilla extract.  Mix in the M&M’s into the batter. Pour the batter into the glass dish and bake for 30-35 minutes until the top is golden brown. Allow to cool to room temperature then cut into bars.

Mark your Calendar!

March: Social Work Month

March 13:   Registered Dietitian Day

March 30: National Doctor’s Day

April 1 – 7: National Public Health Week

April 9 – 13: Patient Advocacy Week

April 22: Earth Day

April 21-27: National Healthcare Volunteer Week

April 21 – 27: Healthcare Administrative

I’m Just A Bill…


S.1203 A bill to amend title XVIII of the Social Security Act to provide for the coverage of home infusion therapy under the Medicare


H.R.2195 To amend title XVIII of the Social SecurityAct to provide for the coverage of home infusion therapy under the Medicare