On April 5, 2006, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule that would require all hospitals to implement a two-step notification process for the discharge of beneficiaries enrolled in traditional fee-for-service Medicare or in a Medicare Advantage (MA) plan.
This Health Alert includes the information the notification must contain, details on the request for review and the operational implications, including the chaotic experience of the skilled nursing facilities and other providers who implemented similar requirements in July 2005.
Hospitals should evaluate the proposed rule carefully given the experiences of other providers who recently implemented similar requirements. Hospitals should consider the practical implications of the proposed rule and submit comments, which are due no later than June 5, 2006, on the inevitable financial and operational burden of these requirements.