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HCA Comments on CMS Discharge Planning Proposed Rule

HCA has submitted comments to the U.S. Centers for Medicare and Medicaid Services (CMS) on its proposal to modify the Medicare Conditions of Participation (CoPs) related to discharge planning requirements for hospitals, critical access hospitals and home health agencies. The proposal was first issued in October.

While HCA supports efforts to revise the CoPs in this area, we commented on several technical and substantive areas of concern, including: CMS’s cost estimates (which fall short of the real impact); implications and possible conflicts with managed care practices; flaws in the publicly reported quality data that hospitals would use for assisting patients in selecting a post-acute provider; the content requirements of discharge summaries; and other issues.

You can download the comments here.