In a recent two-topic S&C letter dated May 12, 2017, the Centers for Medicare & Medicaid Services (CMS) outlined the requirements for notification of transfers and discharges. One of the big changes to Phase 1 of the RoPs required providers to start sending transfer and discharge notices to the LTC Ombudsman Office. CMS now clarifies what needs to be sent and when:
- For Facility-Initiated Transfers and Discharges when a resident is still hospitalized – A discharge notice needs to be sent to the resident, resident representative and the LTC Ombudsman Office at the same time.
- For all other Facility-Initiated Transfers and Discharges – the resident and resident representative, as well as the LTC Ombudsman Office, must be provided with the discharge notice at least 30 days prior to discharge. The LTC Ombudsman Office should be sent its copy of the notice at the same time that the resident/representative are notified.
- Emergency Transfers – Notice of transfer may be provided to the resident and resident representative as soon as practicable. Notice to the LTC Ombudsman must also be sent, but can be sent when practicable as well, including in the form of a list of residents on a monthly basis.
- Resident-Initiated Transfers and Discharges – If a resident initiates the transfer/discharge, providers do not need to send a copy of the notice to the LTC Ombudsman.
Read CMS S&C letter “Implementation Issues, Long-Term Care Regulatory Changes: Substandard Quality of Care (SQC) and Clarification of Notice before Transfer or Discharge Requirements,” (Ref: S&C: 17-27-NH) on the CMS website. You can view our post on the other topic from this memo, Substandard Quality of Care, on the CMSCG Blog.