Hospital transfers and the new Medicare rules…
When we have to facilitate a hospital transfer, we have to shift into high gear. Not only do we have to ensure a safe and smooth patient transition, we have to re-route other facility operations as we shift focus, all while being concerned for our patient requiring transfer, and supportive of our staff. It is even more challenging when a patient is requiring urgent or emergent care and transfer coordination is imminently necessary.
CMS has updated the regs that guide the process as well. Here’s a recommended blueprint to make the process easier.
CMS has changed how it defines a “local hospital”, recognizing that the best facility for transfer may be further than the closest based on the type of care it provides. As an example, a patient with a cardiac emergency may be better served at the hospital five miles away instead of two. If you will be negotiating a transfer agreement, this may impact your hospital selection.
Although not new, as part of your emergency process, your physicians need to have admitting privileges at your receiving hospital or your facility will need a transfer agreement: We need to have one or the other, and the receiving facility needs to be Medicare participating. If you are transferring to a facility where your physician has privileges, check their credentialing file to make sure there is evidence of such and make it part of the credentialing process.
You don’t need a transfer agreement with a transport service, just utilize 911. If the patient requires acute care and is not stable for discharge, best to send them with trained professionals and monitoring. This saves the “how do we transfer” discussion.
One of the new requirements states that we need to communicate to the transferring hospital, and that our policy and documentation supports this. Update your policy to include the communication requirement. If you utilize a transfer form, update the form with a check box indicating the communication took place.
Review your policy to determine if the process supports printing or copying the medical record as part of the transfer. The receiving hospital will want the record. Don’t forget to check out the Advance Directive status of the patient as part of the transfer communication.
Have progress notes with your transfer forms for quick access so the transferring and/or treating physician can document the event. If your anesthesia physician and surgeon are both involved, request they both document.
When the nurse completes and hands off care, have them also document the event as an incident report separate from the medical record.
Utilize a transfer checklist that includes the actions and paperwork involved in the transfer. Include items like belongings disposition, notification of family, to whom report was given, that chart was provided, and that progress notes documenting the event were completed and sent.
I like to maintain an emergency transfer book with the crash cart that includes the policy, forms and checklist so everything is easily accessible when needed.
Practice the process as a scenario for your next code drill, and document the response. You’ll feel more confident if they need to transfer a patient, and the patient will benefit from your preparation.
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