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Draft Plan of Care Discharge Planning
Office of Medical Assistance Programs

December 22, 2000

The Pennsylvania Office of Medical Assistance Programs has released a draft bulletin regarding Plan of Care Discharge Planning. A copy of the draft bulletin is below. Providers who wish to comment on the bulletin should contact Lisa Lowrie at the Association by December 27.

Purpose: The purpose of this bulletin is to remind inpatient facilities of discharge planning requirements.

Scope: This bulletin applies to acute care general hospitals, rehabilitation hospitals, rehabilitation units of acute care general hospitals, residential treatment facilities, psychiatric hospitals and psychiatric units of acute care general hospitals.

Background: Inpatient facilities are required as part of the clinical plan of care to establish discharge plans for the coordination of inpatient services with related community services to ensure continuity of care with the recipients providers of ongoing care, family, school and community upon discharge. The Department has received numerous complaints that frequently inpatient facilities are not assuring the plan is in place before discharging the recipient. In turn this may result in recipients not receiving the care they medically need upon discharge, sometimes with adverse effects.

Discussion:
Federal regulations at 42 CFR §§ 441.155 and 482.43 require facilities to discharge plan. Effective discharge planning should begin at admission and requires internal coordination between the recipient's practitioner and the responsible post discharge planning staff. The facility discharge planner and/or the practitioner must evaluate the recipient's needs for post discharge services to identify patients who are likely to suffer adverse health consequences upon discharge if there is no adequate discharge planning. It is then the facilities' responsibility to see that the plan is in place before the actual discharge. This may include establishing contacts and agreements with the providers of service who are expected to follow through on the plan after discharge. This provides potential outpatient providers the ability to obtain any necessary prior approval from the Department when such approval is required as a prerequisite to implementation of the plan.

Failure of the facility to implement a timely discharge plan is not an acceptable reason for the Department to approve continuation of care at the facility. To avoid fiscal risk it is important for each facility to involve the patient's family in care plans and to start the planning and authorization process for community care in a timely fashion.

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