Cms-r-193 # 24

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HealthAssistance

PartnerSHIP

7

Helping' SHIPSHelp Medicare Beneficiaries

March 6,2007

Bonnie L. Harkless
CMS, Office of Strategic Operations and Regulatory Affairs
Division of Regulations Development - C
Room C4-26-05
7500 Security Blvd.
Baltimore, MD 2 1244-1850
Dear Ms. Harkless:
I am writing on behalf of the Health Assistance Partnership (HAP) with comments on the
Important Message from Medicare. HAP is a non-profit organization whose mission is to
support the State Health Insurance & Assistance Programs (SHIPS) in their work on
behalf of Medicare beneficiaries. We truly appreciate the opportunity to add our
comments to those of other beneficiary advocates. We hope they are helpful to CMS in
its effort to ensure that Medicare beneficiaries receive the highest quality of care.
HAP is concerned that the revised Important Message (IM) lacks clarity about what
patients can expect from the physician and discharge staff as to notice of an impending
discharge. The IM reads, "When your doctor or Plan decides you no longer need hospital
care.. .you will be informed of the discharge date." Who delivers this official notice?
How do they do it; orally or in writing? Who does the patient contact if she or he has
questions? The IM is silent on these critical points. We would prefer alternative
language such as: "When your doctor or Plan decides you no longer need hospital
care.. .your physician or hospital nursing staffor discharge staffwill inform you orally
(or in writing) of your discharge date."
Because a beneficiary's appeal rights will now depend so much on the quality of the
discharge date notice, it is essential for the IM and the hospitals to be clear about the
process. Vagueness on this key point threatens those rights.
We also offer these specific suggestions to improve the IM:
Add space at the top of the IM for the hospital to insert the name of a hospital
staff contact person who is able to answer questions about the IM.
At the bottom of the front page, modify the signature statement to read: "Please
sign below to show that you have received this notice, a hospital staffperson has
fully explained it to you, and you understand it.

1201 New York Avenue, NW, Suite 1100
Washington, DC 20005
Phone: 202-737-6340
Fax: 202-737-8583
E-mail: [email protected]
www.hapnetwork.org

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Require the hospital staff person who discusses the IM with a patient to sign it
also, and add a line for her or his signature under the patient's or representative's
signature line.
We look forward to seeing the final version of the IM, along with CMS's guidance for its
implementation and use. Thank you again for seeking our comments.
Sincerely yours,

Michael Klug, J.D.
Director, Education and Training
Health Assistance Partnership