Next up on the CMSCG Blog “Ftag of the Week” series, we’re looking at a new Ftag, F628 Transfer and Discharge Process. We’re encouraging CMSCG clients to move forward as if there may be no further delays to this guidance becoming effective at the end of March, so we’re looking at everything “new” that you need to know.
In the revisions to State Operations (SOM) Manual Appendix PP, the Centers for Medicare and Medicaid Services (CMS), one regulatory group that was significantly updated includes the tags relating to admission, transfer and discharge. These changes resulted in the development of two new Ftags, F627 Inappropriate Transfer and Discharges, and the F628, which we’ll discuss first since F628 addresses the expectations for “routine” transfer and discharge processes. Let’s start with which tags have been moved to the new F628.
Ftags Going Away – Relocated to F628
When the revised guidance for surveyors goes into effect late in March 2025, we’ll also be saying goodbye to a number of Ftags. However, while there will be less tag numbers to remember, the regulations and their guidance are not going away. Here’s what to know:
- F622 Transfer and Discharge Requirements is split into F627 and F628.
- F623 Notice Requirements Before Transfer/ Discharge is relocated to F628.
- F625 Notice of Bed Hold Policy Before/ Upon Transfer is relocated to F628.
- F660 Discharge Planning Process is included in F627.
- F661 Discharge Summary is included in the requirements for both F627 and F628.
For me, consolidating these tags into one makes sense – and probably could have been implemented in this manner initially. F661 (along with F660) were initially included in the Comprehensive Resident Care Plan regulatory group, so relocating their guidance also makes sense.
F622 – What’s Relocated to F628
As noted above, the revised SOM Appendix PP includes a divvied-up F622. One of the most significant revisions to F622 is CMS’s decision to remove the definitions of “facility-initiated” discharges and “resident-initiated” discharges. Here’s what’s been moved from F622:
Documentation Requirements
- The transfer or discharge must be documented in the resident’s medical record and include the basis for transfer. For some types of transfers and discharges (we’ll review those under F627 in another post), documentation from a physician in the medical record is also required.
- Appropriate and necessary information must be communicated to the receiving healthcare provider. This includes the practitioner’s and resident representative’s contact information, comprehensive care plan goals, advance directives, special instructions/ precautions and any other necessary information to ensure a safe and effective care transition.
F623 Notice Requirements Before Transfer/ Discharge
What to know:
The requirements for the existing regulation at F623 address the facility’s responsibilities surrounding transfer and discharge related to providing notices. Specifically, the facility must:
- Notify the resident and representative – before the transfer or discharge – of the transfer or discharge and the reason in a language and manner they can understand.
- Provide a copy of the notice provided to the resident and representative to the LTCOP.
- Document the reason for the transfer or discharge in the resident’s medical record.
- Ensure the notice includes required documentation (see below).
The required contents of the notice include:
- Reason for transfer/discharge
- Effective date of the transfer or discharge
- Location where the individual is being transferred or discharged
- Statement of appeal rights, including contact information or the entity that receives appeal requests
- Contact information for the LTC Ombudsman Program
- For individuals with ID/DD or MD or related disabilities, the contact information of the appropriate protection and advocacy agency
It’s all about timing, too. Here are some key dates to be aware of:
The notice must be provided at least 30 days before the resident is transferred or discharged.
The notice must be made as soon as practicable before a transfer or discharge when the health or safety of individuals in the facility would be endangered, the resident’s health improves sufficiently to allow for a more immediate transfer/ discharge, an immediate transfer to discharge is required due to urgent medical needs or the resident has not resided in the facility for 30 days.
In Part 2 of our CMSCG Ftag of the Week for F628, we’ll review the other tags being relocated to F628 Transfer and Discharge Process. Those include information on bed hold and discharge summaries.
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