Q: My question concerns the new Conditions for Coverage and the discharge of patient to a "responsible adult." I have in my policy a "responsible person." It is difficult enough for some patients just to get a ride, and if we make it adult-only, I will be canceling patients all of the time. Many people have no adult family members around and I will not discharge to public transport and they never drive. If patient has 17-year-old child, the new Conditions seem to indicate this will no longer be acceptable. Am I interpreting this correctly?
Dawn McLane, RN, MSA, CASC, CNOR, chief development officer, Nikitis Resource Group: Below you will find an excerpt from the Medicare Conditions for Coverage Interpretive Guidelines. If you are a Medicare-certified organization, you must meet the requirement you describe for all patients. The term "adult," in one definition, states "a person who has attained the age of majority (i.e., maturity) as specified by law," so I would suggest that you review how your state defines adult. Your state may define adult as one who has reached the age of maturity, which is often 18, but that may be different from state to state. This is how your policy should read.
However, you may be able to account for discharges to 17-year-olds by including a statement in your policy that says you will not discharge to an individual of not less than [the age of how your state defines an adult] unless one of your physicians writes an order as an exception under circumstances defined within your policy. But any discharge other than to an "adult" would have to be accompanied by a physician order per the Conditions guidelines provided here:
Q-0267
§416.52(c) Standard: Discharge.
The ASC must - (3) Ensure all patients are discharged in the company of a responsible adult, except those patients exempted by the attending physician.
Interpretive Guidelines §416.52(c)(3)
Unless the physician who is responsible for the patient’s care in the ASC has exempted the patient, the ASC may not discharge any patient who is not accompanied by a responsible adult who will go with the patient after discharge.
ASCs would be well-advised to develop policies that address what criteria a physician should consider when deciding a patient does not need to be discharged in the company of a responsible adult. Exemptions must be specific to individual patients, not blanket exemptions to a whole class of patients.
Survey Procedures §416.52()(3) • Do the medical records being reviewed identify for each patient the responsible adult who will accompany the patient after discharge, or, alternatively, a specific exemption for this patient from this requirement by the physician?
Ms. McLane (daquay@aol.com) is chief development officer for Nikitis Resource Group, an ASC development, management and consulting firm with a team that encompasses more than 100 combined years of ASC development and management experience. Learn more about Nikitis Resource Group.