This week’s “Ftag of the Week” on the CMSCG Blog is F623 Notice Requirements Before Transfer/ Discharge. This tag covers everything a nursing home needs to do prior to transferring or discharging a resident to help ensure a safe discharge/transfer. The regulatory requirements for F623 addresses facility-initiated discharges, which is something regulatory agencies will be focusing on more going forward, especially since guidance related to facility-initiated discharges was expanded in the revised surveyor guidance that is effective Monday, October 24, 2022.
Let’s review the definitions in the regulation, starting with those facility-initiated ones.
Definitions
“Facility-initiated transfer or discharge” is a transfer or discharge that was not initiated by the resident through verbal or written request, one is not aligned with a resident’s goals and preferences, or one that the resident objects to.
“Resident-initiated transfer or discharge” by contrast to the above definition, is one that the resident, or resident representative (if appropriate) requests through verbal or written notice. The intent of the notice is that the resident will be leaving the facility without planning to return, and excludes instances where a resident makes a “general” comment about wanting to leave and go home or when a cognitively impaired resident elopes.
“Transfer or Discharge” refers to the movement of a resident to a bed that is outside of the certified facility, not within the same facility. “Transfer” refers to moving a resident from one bed in a certified facility to another, with the expectation that the resident will be returning to the facility. “Discharge” refers to moving a resident from one bed in a certified facility to either another bed in a different certified facility or to a different community location, such as the resident’s home. The resident is not expected to return to the original facility when discharged.
F623 – What’s Required
This regulation addresses the requirement that nursing homes provider notice when the facility is initiating a transfer or discharge. This includes situations where a resident remains in the hospital after an emergency transfer and a discharge is initiated.
Resident-Initiated Transfers
Residents may initiate a transfer or discharge in writing or provide verbal notice of their intent to leave the nursing home, including to take a therapeutic leave, which is a form of resident-initiated transfer. When a resident provides this notice, his/her record must include documentation of:
- Resident/Representative’s verbal or written notice of intent to leave the facility
- Comprehensive Care Plan that includes the resident’s goals for admission and desired outcomes, including for discharge
- Discharge care plan
- Documentation of discussions with the resident/representative regarding arrangements for post-discharge care and other details of the discharge planning process
Ensuring the resident record reflects these proactive and collaborative steps to ensuring a safe discharge will help to clarify whether a discharge was indeed initiated by the resident or not, should that become a concern. The Interpretive Guidance (IG) states that surveyors are expected to determine if a transfer or discharge was initiated by the resident or the facility. The surveyor will review the above items, and if needed, conduct interviews and additional record review.
In Part 2 of this post, we will look at the provider’s responsibilities related to the contents and timing of notices of transfer or discharge, as well as some actual survey citations.
