Comment #23

Samaritan
Health Sentices

3600 NW Samaritan Drive

Corvallis, OR 97330

www.samhealth.org

Building healthier communities together

Samaritan Health Services comments on CMS Revised Version of the Important
Message from Medicare (IM) (CMS-R-93).
Samaritan Health Services is a network of non-profit hospitals, physician clinics, senior
care facilities and health plans serving Oregon's Mid-Willamette Valley and Central
Oregon Coast. This letter serves as Samaritan's public comments on the CMS proposed
Revised Version of the Important Message from Medicare (IM) (CMS-R-93).
As published, the revised rule sets forth requirements for how hospitals must notify
Medicare beneficiaries who are hospital inpatients about their discharge appeal rights.
While CMS was well intentioned in proposing this rule in response to concerns raised by
advocacy groups with respect to hospital discharge planning processes, Samaritan Health
Services believes this rule will pose several challenges.
Samaritan Health Services has three comments:
First, it is the opinion of Samaritan Health Services that the proposed Revised Version
will create a duplication of already existing efforts to provide patients with the Important
Message from Medicare. Patients are already provided with the Important Message fiom
Medicare upon admission. Further, the average length of stay (LOS) for patients is 4 to 5
days. It is our opinion that it would be redundant and potentially create confusion to
provide a patient whose LOS is 4 days with the Important Message on day one and again
two days later.
Second, the provision would further require that the second copy of the Important
Message be given again two days prior to discharge. Samaritan Health Services believes
that it could not in good faith accurately and consistently estimate the discharge date of a
patient, and therefore could not ensure the two-day period be met consistently.
Third, Samaritan Health Services believes that the provision would create an additional
burden of expense and staffing in the areas of monitoring a patient's LOS to ensure the
two-day prior to discharge mandate is met; providing a secondary form to patients or
their representative and the cost of the form itself
Samaritan Health Services appreciates the opportunity to provide additional comment
regarding the CMS Revised Version of the Important Message from Medicare.
Submitted by:
Colleen Fair, Director Regulatory Compliance & Accreditation Oversight
Samaritan Health Services

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Building healthier communities together

Marti Cersovski
Dlrector
Market~ngand Public Reiattons
815 NW 9th Street. S ~ I I254
~ P Corvallls, OR 97330
wwwsarnheaithorg
mart1 rerso~,sk~:dsamhealthorg
1541) 768~4693 f a x (541I 768-501 7