Discharge Planning in Hospitals – Two Important Clarifications

Dr. Ronald HirschNovember 9, 2023

In 2019 the Centers for Medicare & Medicaid Services (CMS) adopted significant changes to the hospital discharge planning conditions of participation. As most know, the conditions of participation are rules by which a medical provider must abide to be able to provide care to Medicare and Medicaid patients and any other federally funded health care programs. The hospital conditions of participation can be found in Title 42, part 482 of the Federal Regulations and includes 25 subparts, encompassing everything from the medical staff and nursing services to food and dietetic services to infection prevention to fire safety, and of course discharge planning.


These discharge planning conditions were rewritten partially in response to the IMPACT Act, a law passed in 2014 that is intended to change and improve Medicare's post-acute care services and how they are reported. The law required CMS to develop standardized methods of reporting patient assessment data, quality measures, and resource use data. The result of that law was the development of the CMS website Care Compare, now called CMS Compare, which collects such data and presents it in a consumer-friendly way.


There were several significant requirements in the revamped conditions of participation that led to process change within hospitals. First, CMS requires that patients be offered the choice of any post-acute provider that can provide the necessary care and serve the geographic area where the patient wishes to receive care. In the past, hospitals would find an available post-acute provider and refer the patient there, without any input from the patient. They now must produce a list of all qualified providers including, at a minimum, the CMS Compare data on quality of care and resource use for each provider.


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Author Bio: Dr. Ronald Hirsch is Vice President of the Regulations and Education Group at R1 RCM Inc. Dr. Hirsch was a general internist and HIV specialist and practiced at Signature Medical Associates, a multispecialty practice located in Elgin, IL. He was Medical Director of Case Management at Sherman Hospital in Elgin, IL from 2006 to 2012, where he was Chairman of the Medical Records Committee from 1995 to 2012, and also served on the Medical Executive Committee. Dr. Hirsch is certified in Health Care Quality and Management by the American Board of Quality Assurance and Utilization Review Physicians, certified in Revenue Integrity by the National Association of Healthcare Revenue Integrity, and on the Advisory Board of the American College of Physician Advisors. He is on the editorial board of RACmonitor.com. He is the co-author of The Hospital Guide to Contemporary Utilization Review, with the third edition published in 2021.

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