As mentioned in Part 1 of our Ftag of the Week for F628 Transfer and Discharge Process, several Ftags are being relocated to this new Ftag. Given that we didn’t have the opportunity to do an “Ftag of the Week” for F625 Notice of Bed hold Policy Before/ Upon Transfer, we’ll go into more details regarding these requirements. Bed hold requirements will be part of F628 when the revised surveyor guidance becomes effective – less than 3 weeks from now.
F625 Notice of Bed Hold Policy Before/ Upon Transfer
Let’s start with a review of key definitions – all of which are included in the new F628:
Bed hold is defined in SOM Appendix PP as holding or reserving a bed for a resident when he/she is absent from the facility for hospitalization or therapeutic leave.
Reserve Bed Payment refers to payments made by a state to the nursing home to hold the resident’s bed during his/ her temporary absence from the facility.
Therapeutic leave is defined as a resident’s absence for purposes other than a required hospitalization. The Interpretive Guidance notes that therapeutic leaves of absence must be:
- consistent with the resident’s goals of care
- assessed as part of the comprehensive assessment
- incorporated into the resident’s CCP
Therapeutic leave may not be used as a means of discharging a resident against his/her stated goals or wishes. That’s new language that’s been added to the IG, so expect that surveyors will be looking to see if a resident went home for a nice visit with family and was expected to return to the facility, but it was used as an opportunity to discharge the resident.
What’s Required
Medicaid requires each State’s Medicaid Plan to address bed hold, and the plans can vary. Bed hold for absences which exceed the State’s limit are considered non-covered, but the resident/ representative could pay privately for the bed hold. If the resident does not wish to pay privately, the expectation is that the resident would be permitted to return to the nursing facility to the next available bed, so long as he/ she needs services provided by the facility and is eligible for SNF/NF services.
Providers are responsible for policies which include certain information which must be provided to residents/ representatives.
- The facility must have a policy that addresses holding a resident’s bed during temporary absences.
- The facility must provide written information to the resident/ representative regarding this policy prior to and upon transfer. This means there are two notices provided regarding bed hold. The first is typically provided during admission. The second needs to be provided at the time of transfer.
- All residents must be provided with this information, regardless of payment source.
Before a resident is transferred to the hospital or goes on therapeutic leave, the facility is required to provide written information to the resident or representative that specifies the duration of the State bed-hold policy (if there is one) and the reserve bed payment policy under the State plan (if applicable). This is the second of the two required notices.
The facility’s policy must reflect bed hold periods which are consistent with the requirements above. So, even if your State plan does not include bed hold, you still need to have a policy which reflects that information. The notice should also address how the facility permits a resident to return to the next available bed.
Important compliance reminder – All nursing homes are required to have a Bed Hold Policy – even if the facility does not have bed hold. CMSCG clients sometimes tell us during a mock survey that they don’t “do” bed holds, so therefore don’t have a policy. This would not be compliant with regulatory expectations.
In Part 1 of our CMSCG Ftag of the Week for F628, we discussed various timeframes, and there are timeframes associated with this notice as well. What to know:
- The written bed hold policy notice must be provided to the resident and representative at the time of transfer for hospitalization or therapeutic leave.
- If the transfer is an emergency transfer, the notice must be provided within 24 hours.
It’s important to ensure there is documentation that this notice has been provided. The IG states that there should be documentation of “multiple” attempts, if necessary, to provide the information to the resident representative.
In Part 3 of this Ftag of the Week series, we’ll review the last part of the requirements for F628 regarding the discharge summary.
About CMS Compliance Group, Inc.
CMS Compliance Group, Inc. is a regulatory compliance and quality improvement consulting firm with extensive experience providing services to post-acute and long-term care providers. With the idea of continuous quality improvement in mind, CMSCG’s interdisciplinary team provides a unique approach to client service, ensuring that all disciplines can achieve and maintain compliance while improving quality of care.
Our experienced consultants provide proactive and reactionary compliance consulting services to clients throughout the United States. CMSCG has an established reputation for rapidly addressing and successfully resolving the most serious issues that occur in nursing homes, assisted living facilities, home health agencies, VA Homes (CLC/ SVH), adult day care programs and other providers. Contact us to learn more about our services.
One thought on “Ftag of the Week – F628 Transfer and Discharge Process (Pt. 2)”