The OIG recently released a review of SNF care and discharge plans. The OIG found that 37% of SNFs did not meet the care planning requirements or did not provide services in accordance with care plans. They go on to say that for 31% of stays, SNFs did not meet discharge planning requirements. The OIG calls for stricter oversight of SNF care and discharge plans as Medicare paid approximately $5.1 billion for stays in which SNFs did not meet the requirements.
What this means for you
You can expect surveyors to pay very close attention to care and discharge plans. When the federal government identifies $5.1 billion in payments for services that did not meet requirements, you can read that to mean they consider these over/erroneous payments. Enforcement activity is at an all-time high with SNFs making large repayments to the government. Expect the survey process to include a detailed review of the care plan content versus the actual services provided.
What the OIG recommends
- Strengthen the regulations on care planning and discharge planning
- Provide guidance to SNFs to improve care planning and discharge planning
- Increase surveyor efforts to identify SNFs that do not meet care planning and discharge planning requirements and to hold these SNFs accountable
- Link payments to meeting quality-of-care requirements
- Follow up on the SNFs that failed to meet care planning and discharge planning requirements or that provided poor quality care
How to protect yourself
SNFs can protect themselves from this additional regulatory scrutiny through care plan training and auditing. Remember, care plans must be individualized and consistently updated. Include measurable objectives and timetables to meet a resident's medical, nursing, mental and psychosocial needs identified in the MDS assessment. Conduct a review of care plans to ensure the MDS data links to the care plan, stated goals include a measurable objective, timetables are reasonable, and documentation in the chart is consistent with the plan. Once you develop a baseline understanding of your current state of compliance with care planning requirements, perform staff training consistent with the gaps in your care planning process. Follow up with a regular care plan audit.
Discharge planning is also a key focus area for investigators. Your audit should include a specific review of discharge plans relative to the requirements. Discharge plans should include a thorough recap of the resident's stay, a description of the resident's functional status at the time of discharge, and a description of the care and services required following discharge. Resident needs and plans change frequently, so re-visit the subject of discharge periodically even if there is no short-term plan. Be certain that care plan meetings include a discussion about each resident's discharge potential and the likelihood that the resident will elect to leave. Keeping an open dialogue will give your facility the time it needs to plan discharges appropriately and safely.