What CMS’s Final Rule on Patient Data Sharing Means for You and Your Post-Acute Network

by Karen Underwood on Nov 25, 2019

computer screen showing a senior home listing

On November 29, 2019, the Centers for Medicare and Medicaid Services will finalize a rule meant to ensure appropriate data is provided to patients and their families when they’re making their decision about a post-acute care (PAC) provider.


Addressing Quality and Resource Use Data During Patient Discharge


We expect numerous Ensocare customer hospitals to be impacted by the new rule. However, for the vast majority of organizations, we do not expect this to lead to a complete overhaul of current policy regarding patient steerage and post-acute care selection, especially if you’re a current Ensocare Choice customer. Remember, Ensocare Choice will enable you to:

  • Provide relevant PAC data to patients
  • Present and compare PAC facilities with the patient
  • Document the patient’s choice of PAC provider
  • Stay compliant with CMS’s Final Rule

Here are the top-level takeaways from the new rule that case managers, discharge specialists, and hospital policymakers need to know:


Applicable PAC facilities that hospitals should be sharing data about include:


  • Skilled Nursing Facilities
  • Long-term Care Hospitals
  • Home Health Agencies
  • Inpatient Rehabilitation Facilities

Best efforts must be made to share data from all facilities providing post-acute care that a patient could be expected to check into. This might also include such non-healthcare entities as group homes, shelters, subsidized housing and more.


What Data Should I Be Sharing with Patients?


Relevant Types of Data Include:

  • Skin Integrity
  • Major Fall Incidents
  • Resource Use
  • Community discharge
  • Special Services

There are more data sets you can find on the CMS Website. Medicare provides a great resource on applicable data and comparisons via their web portals:​inpatientrehabilitationfacilitycompare/​​homehealthcompare/​search.html​nursinghomecompare/​search.html​longtermcarehospitalcompare/​


How does this impact compliance?


In order to ensure your facility is compliant, you must meet six thresholds:

  • Quality and resource use data is applicable to the patient’s care goals and treatment preferences
  • Data is presented objectively
  • Data on available PAC providers meeting the patient criteria is presented
  • Patients are informed that they have a choice in their PAC selection
  • Patient is allowed to make their PAC selection
  • Interactions up to and including their final selection are documented in the medical record

CMS has made a few stipulations that ease the burden for hospitals. As you go about presenting data to your patients, remember these three things:

  • Interpretation and discussion of the data can be at the most basic level
  • Overly complex and detailed analyses aren’t just unnecessary, they are discouraged
    • CMS wants caregivers to interact with their patients in a way they can easily follow and understand
  • Data that is difficult to ascertain or does not exist is unnecessary to include or take pains to find
  • Caregivers should answer patient questions to the best of their abilities
    • However, if the answer is unknown or would require an unreasonable amount of additional input, there is leeway in how much can and should be presented in regard to the question


Let us know if you have any questions and if there’s anything we can do to help you initiate the successful, seamless and compliant discharge of your patients to a post-acute care facility that meets each individuals’ care needs.

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Meet the Author

As Executive Director of Product Development, Karen Underwood is responsible for the company’s product strategy and ensuring the product portfolio exceeds customer expectations. With more than 20 years of software and product management experience, Karen leads the product management and development teams. Karen is a graduate from the University of Nebraska-Lincoln. She also has certifications from the Healthcare Information and Management Systems Society and the Pragmatic Institute for Product Management and Marketing.