Hospital staff members have a few choices when deciding how to distribute the Important Message from Medicare (IM) regarding discharge appeal rights. However, the hospital operational staff should find the method that best suits the size of the hospital and the roles of the staff members. In 2007, CMS required hospitals to give Medicare inpatients a revised version of the IM to explain beneficiaries’ hospital discharge appeal rights.

Beneficiaries receive the notice twice, according to the regulations. The first time should be “up to seven days before or within two calendar days of admission,” according to CMS. At that time, the hospital “must obtain the signature of the beneficiary or his or her representative and provide a copy” to the patient. The hospital gives the patient his or her signed notice a second time “as far in advance of discharge as possible, but not more than two calendar days before discharge,” CMS states.

Distributing the notice

Hospital staff members can easily distribute the IM the first time during patient admission, says Kimberly Hoy, JD, CPC, regulatory specialist at HCPro, Inc., in Marblehead, MA.

The second distribution is a little trickier because it is difficult to predict the time of a patient’s discharge, Hoy says. CMS prohibits hospitals from having a routine policy to hand the patient the notice on the day of discharge, which further complicates the process. Also, hospitals must ensure that a qualified staff member, such as a case manager, hands the patient the IM and answers any questions he or she might have, Hoy says. However, case managers generally do not work weekends.

Deciding on a method

Some hospitals adopted an organized method, designating a qualified person, such as a case manager, to hand out the IM every Monday, Wednesday, and Friday in case patients should be discharged in the ensuing two days. Since this duty would take a case manager away from discharge planning, this process would probably work best for larger hospitals that can afford to assign a case manager solely for this purpose, Hoy says.

“When you have the volume that some of the larger hospitals have, you need a systematic process,” she says, adding that this method ensures the designated person delivering the notices is qualified to answer patients’ questions.

Unit clerks play a major role in distributing the IM at Mercy Health Partners’ (MHP) five hospitals in Ohio. At MHP hospitals, registration staff members give the patient the IM at admission, and the unit clerks hand it out the second time prior to discharge, says Beth Hickman, MHP’s regional director of corporate responsibility.

Unit clerks generally perform nonclinical administrative tasks in a hospital unit. Their duties vary, so this method may not work at all hospitals, depending on what roles unit clerks play, Hickman says.

“The unit clerks get a list of all the Medicare patients, and they consult with the nurses to find out when the patient is expected to go home,” she says. Then they determine whether the patient can sign the form or who can sign it if the patient is unable.

Because unit clerks work near patient rooms all day, they can see whether a patient’s family visits. This makes it easy for them to get a signature from the patient’s healthcare proxy, Hickman says. “That’s how we’ve done it. It’s actually worked out pretty well for us,” she says. The process gives unit clerks added job responsibilities and a chance to interact with the patients.

Although unit clerks can distribute the IM, Hoy says, whoever hands it out needs to be qualified to answer a patient’s questions regarding his or her discharge. Patients might want to know why they no longer need inpatient care or what kind of care they will need after discharge.

Preventing appeals

Medicare beneficiaries have the right to appeal the discharge decision by calling the affiliated quality improvement organization (QIO). The telephone number is printed on the IM.

However, some appeals pose financial harm for hospitals. For example, if a patient makes the call to the QIO to appeal on a Friday night, he or she will likely leave a message on an answering machine. By the time the QIO processes the appeal and gives its decision, it is noon on Tuesday. The patient does not have to pay for his or her care between the time of appeal and the time the hospital discharged the patient on Tuesday, resulting in a loss of money and resources, Hoy says.

To avoid the appeals process, Hoy suggests a premeditated strike of sorts.

Hospitals have the opportunity to provide a patient with a detailed notice of discharge (DND) in addition to the IM. Hospitals are required to provide the patient with the DND after the patient appeals his or her discharge. However, the DND can also be given out prior to a possible appeal. If a nurse or case manager feels that a patient is likely to appeal, they should distribute a DND, along with applicable Medicare policies and documentation showing why the patient no longer meets inpatient care criteria, Hoy says.

The more information the facility provides to patients regarding discharge planning and ensuring that patients have an appropriate place to go, “the safer they’re going to feel leaving the hospital,” Hoy says.

Electronic medical records can aid in auditing IMs

Auditors and compliance officers can easily audit their hospital’s IM distribution practices, Hickman says. Some of MHP’s facilities have electronic medical records, which make the auditing process a cinch. They use document imaging to scan the signed IM into the patient’s medical record.

“I can go in from my desk, pull a record, and look to see whether I’ve got a signed IM in that electronic health record,” Hickman says. “It’s really very nice.”

Some of MPH’s facilities do not have electronic medical records; however, auditing is still fairly simple, Hickman says. She suggests multitasking.

“It doesn’t take that much time to go in and look for it when you’re looking at records for other things,” she says. “It’s a matter of being cognitive of the fact that it’s one more thing you’re going to need to audit for.”