You are right, CMS has never clarified this, but needs to. How long do you wait before you consider a resident's discharge to be final? If you discharge a resident Return Anticipated and they come back 2 months later, what happens if no Significant Change has taken place. Under the current written regs, you are not required to do anything. CMS has always gone under the assumption that anyone gone that long probably has had a significant change. While that may be true most of the time, I feel it is an unnecessary ambiguity in the regs.
 
I would like to see the regs changed. I propose that anytime a resident is discharged Return Anticipated and is gone from the facility more than 14 day, that discharge is considered final. If they then return, a new Admission assessment should be required.
 
This addresses a couple different problems. First, it makes things simpler for the RNAC to understand without requiring much additional work. Since you end up doing a SCSA most of the time it probably is no extra work. Second, since under the current reg a facility has the option fo doing  a new Admission Assessment following a Discharge Return Anticipated, this would eliminate the confusion that arises from a new AB1 following the Discharge Return Anticipated.
 
 
Nathan
----- Original Message -----
Sent: Sunday, January 25, 2004 9:11 AM
Subject: Re: SCSA mds or not?

When a resident is going to be gone more than 10-14 day I usually suggest doing the Discharge Return not anticipated even if you expect the resident back. Several years ago (I don't remember exactly when) HCFA came out with guidance (not a written reg)  that a resident gone more than that time period should be considered to have been finally discharged.


Just to be clear - this has never been formalized and is not a part of current CMS policy.

When a resident is expected to return to the facility (the physician or resident/family has not stated that the resident will not be returning), the  Discharge-Return Anticipated is the correct tracking code.  With a Discharge-Return Anticipated, regardless of the time period the resident is out of the facility, upon his or her return, a new Admission assessment is not required nor is it necessary, since the resident would be assessed upon return to the facility to determine if a Significant Change in Status Assessment is required.

If a resident was discharged with return anticipated and the facility determines that the resident will not be returning or has died, the facility has the option to complete another discharge tracking form with the code Return Not Anticipated.  Though it is not required, it keeps the records tidy.

See page 2-24 of the RAI User's Manual as well as the Discharge and Reentry Flowchart on page 2-26 for requirements pertaining to these tracking forms.

Rena

Rena R. Shephard, MHA, RN, FACDONA, RAC-C
Chair, American Association of Nurse Assessment Coordinators
[EMAIL PROTECTED]

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