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What if Rehab Wants to Discharge Too Soon?
When a parent is transferred from the hospital to a rehabilitation facility, many sons and daughters breathe a sigh of relief because they believe their parent will now have 100 days to gain strength and mobility.
Too bad that's not necessarily true.
Just like hospitals, rehabilitation facilities also have to worry about meeting Medicare guidelines and being paid. And just like hospitals, some may take the path of least resistance and discharge their rehab patients too early.
If you have been told that your parent will soon be discharged from inpatient therapy, and you believe it is much too soon, here's an action plan:
How to Appeal a Discharge From Medicare Rehabilitation
When you hear about a planned discharge date, the first thing you should do is read the progress notes written by your parent's therapists. If you see notes that reveal your parent has stopped making progress for several days, then perhaps the facility is correct. However, if you see written documentation from the therapists that your parent is continuing to make progress, then you can protest the planned discharge. Get copies of these notes if you can.
As soon as possible, make arrangements for a friendly meeting with at least one of your parent's primary therapists and the discharge planner/social worker. The discharge planner/social worker is not the one making therapy decisions, so meeting with the discharge planner alone is not sufficient for the information you need.
If the therapy decision-makers are not willing to extend their planned discharge, verbal notice to you or your parent is not sufficient. They must give your parent a written Notice of Medicare Provider Non-Coverage (NOMPNC) form at least two days before the anticipated discharge date. On that form there will be information about how to contact the relevant "Quality Improvement Organization" (QIO). The QIO is the group that reviews these cases and makes determinations about whether care should continue.
If you haven't received a NOMPNC at least 2 days before the discharge date, the facility has to keep your parent until at least two days after you do receive it.
By latest noon on the calendar day before care is scheduled to end you should contact the QIO to lodge an appeal. You can do this by telephone. Make a note of the date and time of your request, and the name of the person who took your request. The QIO will then immediately ask the rehab facility to submit specific documentation about your parent. You have a right to ask for a copy of everything the facility submits (this is why you wanted copies from the chart...you want to be sure the information matches).
If you made your review request before the deadline, the QIO must make a decision by the end of the day AFTER the NOMPNC document said services were to end (or, within 72 hours after the time you requested the review if you did it right away).
If the QIO agrees with your appeal, then Medicare will continue to cover your parent's rehabilitation. When the facility sets another discharge date, you can go through the same exercise again, if appropriate.
If the QIO review agrees with the facility that the scheduled discharge is appropriate, then you will have to either take your parent out, or pay privately for any care past the date of discharge.
Or, you can choose to continue to appeal up the ladder. However, if you lose your next appeal, you will have to pay privately for all the days your parent was in the facility receiving therapy after the originally stated discharge date. The rehab won't be able to bill you until after your appeal is exhausted, but you will owe if you lose.
Medicare HMOs (Advantage plans) have similar appeals processes. If your parent participates in an Advantage plan, ask about their individual appeal procedures.
If you decide not to appeal, or if your appeal for more rehabilitation is denied, your parent will have three options: a) remain in the facility as a long-term resident, paying privately; b) move to an assisted living or other nursing facility; C) return to his own or a relative's home. If he chooses option b or c, he will be able to continue rehabilitation therapy at home through traditional Medicare Home Health or a participating Advantage home care program. Be sure that the discharge planner sets this program up before your parent leaves the facility.
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