OIG Issues Report Critical of SNF Care and Discharge Planning

On February 27, 2013, the Office of the Inspector General of the Department of Health and Human Services (OIG) released the results of a study of care and discharge planning by Skilled Nursing Facilities (SNFs).  The report found that over one-third of patient stays in 2009 failed to meet Medicare requirements in these areas.

SNFs are required to develop and provide services in accordance with a plan of care for each Medicare patient.  This must be a customized plan describing how the SNF will meet each patient’s medical, nursing and psychosocial needs, including measurable objectives and time tables for care.  However, the OIG survey found that SNFs either did not develop an adequate care plan or did not provide care in accordance with the plan 37% of the time.  The most common deficiency found was that the plan of care failed to address an area, such as a high risk for pressure ulcers or falls, identified in the initial patient assessment.

SNFs are also required to develop a discharge plan that includes a summary of the patient’s stay, the patient’s status at discharge, and a post-discharge plan of care.  The same OIG survey found that 31% of discharge plans did not properly address at least one of these elements.

The OIG estimated that SNFs received approximately $5.1 billion in Medicare reimbursement for patient stays in 2009 that did not meet regulatory requirements for plan of care and/or discharge planning.  The OIG has recommended that CMS take the following steps to address this issue:

  1. Strengthen regulations on care and discharge planning;
  2. Provide additional guidance to SNFs on these topics;
  3. Increase surveyor efforts in this area;
  4. Link payments to meeting quality of care requirements; and
  5. Follow up with SNFs that failed to meet these requirements.

CMS has indicated that it agrees with and is considering steps to implement these recommendations.

SNFs should consider reviewing their current plan of care and discharge planning policies and procedures to make sure they are meeting their Medicare obligations in anticipation of increased focus by surveyors and auditors on this area.  The physicians, nurses and other professionals who develop each patient’s plan of care need to ensure that it addresses all problem areas identified in the initial patient assessment.  Caregivers need to be educated about the importance of following each patient’s plan of care and clearly documenting this in the patient’s medical record.  If deviations from the plan become necessary because of changes in the patient’s medical condition or other causes, these reasons should also be documented.

When preparing for discharge, the SNF must make sure to include all the information patients and their next care providers will need.  Discharge plans should be issued to each patient in writing, and a copy should be retained as part of the patient’s medical record.

The complete report issued by the OIG can be found here.

For more information on the OIG report or related issues, please feel free to contact Janet Feldkamp, Kelly Skeat or any member of our health care practice group.

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