The Centers for Medicare and Medicaid Services (CMS) requires that all Medicare inpatients receive written information about their discharge rights. 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 on admission and before discharge.
- The IM form is an Office of Management and Budget (OMB) approved form and cannot be altered from its original form.
- The timeframe for the delivery of the form is clearly spelled out in the Condition of Participation (CoP) §482.13(a)(1), as illustrated in this table.
- The designee response 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.
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. Click here to download a sample policy that details the admission and discharge procedures and the discharge appeal process.
To ensure compliance, you must 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.
While most hospitals have achieved compliance with delivery of the form on or before admission, many struggle with compliance in delivering the form at discharge. The America Case Management Association (ACMA) met with CMS officials to discuss results of the ACMA Public Policy Committee’s survey about the delivery of the second IM. The results of the survey include the following findings:
- The majority of respondents (84%) report that case management is responsible for issuing the second IM.
- More than half the respondents (59%) report that issuing the IM requires 10 minutes or less.
- More than 77% of respondents report that they track IM compliance.
- Of those who track IM compliance, 40% report a compliance rate between 76% and 100%.
- Only 38% of respondents report increased numbers of patient appeals.
- The majority report that less than 25% of patient appeals are successful.
- Respondents generally feel the second IM process adds little value to patient care but contributes to patient confusion and frustration.
According to the ACMA, CMS was “receptive to the feedback.”
The latest versions of the IM, Form CMS-R-193, and the “Detailed Notice of Discharge”, Form CMS-10066— updated as of July 20, 2010—along with instructions, are posted on the CMS website. This latest version of the IM requires hospitals to note the time of delivery. After April 1, 2011, the forms with approval dates of 05/07 are not valid.
For more information on compliance with the Important Message from Medicare or for an editable version of the sample policy, contact our office at (513) 241.0142 or send us an email.