Late CMS-R-193 Comment #25

1414 Kuhl Avenue

Orlando, Florida 32806-2093

(407) 841-5111

March 5,2007

Bonnie L. Harkless, Room C4-26-05
Office of Strategic Operations and Regulatory Affairs
Division of Regulations Development - C
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, Maryland 21244-1850
RE: (CMS-R-193) Important Message from Medicare (72 Federal Register 568), January 5,2007
Dear Ms. Harkless:
Orlando Regional Healthcare appreciates the opportunity to comment on the Centers for Medicare &
Medicaid Services' (CMS) proposed revisions to the Important Message fiom Medicare (IM), as
published in the Federal Register dated January 5,2007.
Listed below are some of our concerns and comments:
Availability: As indicated, will the QIO be available 7 days a week / 24 hours a day?
Process: We are continuously moving to a paperless operation. While we are instructed to provide the IM
within two days of admission and the patient is to sign the form and provide a copy of the signed notice
prior to discharge (but no more than 2 days before the discharge), is there a pldacceptance for patients to
sign via signature pad or must the document be signed in paper format and scanned into the hospital
record?
Patient inability to understand andlor sign the document: Being a Level 1 trauma center, we are concerned
about instances when a Medicare patient is admitted to the hospital and is unable to understand and/or
sign the document and no representative is available (either in person or by phone) or there is no
representative for the patient. What procedures do we implement in these situations?
Patient refusal to sign the form: What procedures should we follow in these instances? If we are required
to note the refusal and have the form witnessed, there is no area available to complete this process.
Layout and design of the proposed form:
Will CMS provide the form in different languages? In what language will they be available
and when?
Can the form accommodate a patient's mark or an X if that is their signature?
No space on the second page to indicate the name and phone number of the Medicare
Advantage plan, although the instructions call for this information to be completed.
Form appearance is very busy - could this be designed for easier reading and understanding
by the patient? Can an education sheet be developed for layman explanation of the form?

Orlando Regional Medical Center Arnold Palmer Hospital for Children & Women Orlando Regional Sand Lake Hospital
Orlando Regional St. Cloud Hospital Orlando Regional South Seminole Hospital South Lake Hospital
M. D. Anderson Cancer Center Orlando Orlando Regional Healthcare Foundation

1414 ICuhl Avenue

Orlando, Florida .32806-2093

(407) 841-5111

Although the comment period has expired for comments related to the overall process, we would like to
again communicate our comments, concerns and questions:
Adds unnecessary burden (very labor intensive) to hospitals and managed care plans
who perform the function as well as increased costs for paperlstaff time, etc.
Very difficult (if not impossible) to determine discharge date
Difficulty in reachmg the patient representative if patient is incompetent /
unresponsive
May cause delayed discharges to allow hospitals to satisfy the notice requirement;
may conflict with the discharge planning process
Overall it may effect: efficient patient flow, bed capacity, patient transfers to
different level of care, loss of bed availability in skilled nursing facilities and Rehabs
If patient's discharge is delayed due to notice requirement, will DRG payments be
adjusted for increased length of stay coverage?
Possible increased potential of med errors, hospital inquired infections, falls, etc.
Increased workload / burden on nursing, Patient Business, Case Management designated department(s) must deliver this process
Coordination of issuance with managed care plans
Increased concern / confusion on the part of the patients (elderly population)
How to track distribution of the IM not more than 2 calendar days before discharge
Could there be a reconsideration for IM to be provided to Medicare patients with a 30
day or greater length of stay

.

Orlando Regional Healthcare again thanks CMS for the opportunity to comment on the revised
IM. If you have questions on these comments, please do not hesitate to contact me at (321) 841-8026 or
via email at [email protected].
Sincerely,

n

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n zno CI,
Sandy Perrott '
ManagerlCase Management
Orlando Regional Healthcare

Orlando Regional Medical Center Arnold Palmcr Hospital for Children 0Women Orlando Regional Sand Lake Hospital
Orlando Regional St. Cloud Hospital Orlando Regional South Seminole Hospital South Lake Hospital
M. D. Anderson Cancer Center Orlando Orlando Regional Healthcare Foundation