Late Comment

Post Office Box 1000
Fishersville, Virginia 22939
540/332-4000 .540/932-4000

AUGUSTA MEDICAL CENTER

FAX 540/332-4809

FAX 540/932-4809

March 19,2007
Leslie Norwalk
Acting Administrator
Centers for Medicare and Medicaid Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W., Room 4 4 5 4
Washington, DC 20201

RE: CMS Proposed Revision of the Important Message from Medicare and Related
Paperwork Requirements (Vol. 72, No. 3), January 5,2007
.Dear Mr. N o d :
Augusta Medical Center, a medium-sized, private, not-forprofit, community hospital apprecktes the
opportunity to comment on the Centers for Medicare and Medicaid Services' (CMS) proposed
revision of the "Important Message from Medicare" (IM) and its related paperwork requirements as
submitted to the Office of Management and Budget. This revision seeks to implement revised
regulattons on how hospitals will no@ Medicare beneficiaries of their hospital discharge appeals
rights as published in the Federal Register of November 27,2006.
Despite the modifications that have been made to the proposed rule, they still impose significant
administrative burden to hospitals, especially those of our size with limited resources to apply
towards fulfilling the additional administrative requirements.

As you are well aware, hospitals across the country dwrent provide the Important Message from
Medicare to beneficiaries when they are admitted to the hospital as part of their admission
i n f o d o n . This Message provides a very thorough explaoation of the beneficiaries' right to have
their discharge decision reviewed by the local Quahty Improvement Organization (QIO) if they
believe they are being discharged too soon. The Message provides all the information needed by the
beneficiary to request such an appeal and also explains that they will not be held financially liable for
continued hospital care while the QIO reviews their case.
Under this new regulation, which is plarmed to become a v e July 1,2007, the IM must now be
given no later than 2 days following admission, and must include the beneficiary's signature
documenting that the beneficiary received it, that it was explained to herhum, and that shehe
understads it. Furthermore, the hospital must provide a second copy of the signed Message to
beneficiaries no more than two days prior to discharge.
Augusta Medical Center urges ClMS to reconsider these regulatory requirements in relation to
the cost/benefit burden they will place on hospitals across this country, especially those where the
resources required to meet these requirements are already limited.
CMS has projected that implementation of these proposed regulations will increase Mtime from
208,333 hrs to 2,990,000 hrs-a more than 14-fold increase. This is patient M t i m e and attention
that is being taken away from bedside care and patient dkty idiatives that truly impact patient
satisWon. Most hospitals, incluchg AMC, already expend an enormous amount of resource in

discharge planning. AMC's nursing staff, case managers and social workers begin the discharge
planning process at the time of admission. Many hours and long days are spent with families
assisting them with aAer care needs-be it home health,
- . procurement of home medical supplies,
nursing home placement or hospice care,etc. Adrmntstratve burdens such as these take away h m
the time and attention that is needed to achieve the best outcome for the went and f b i l y so that
discharge occurs in a safe and satishcbry manner.
If a second notice is indeed required, Augusta Medical Center strongly requests that CMS
consider eliminating the requirement that the repeat notice be given no more than 2 days prior
to discharge. Simply allow a copy of the Message to be given on the day of discharge as part of the
discharge htructions that all patients routinely receive.
Conduct an evaluation of benefit after the first year to see whether #is new process has yielded
sufficient benefd to warrant the significant cost to its burden. History has already demonstrated
that getting beneficiariesto sign the notice was unnecessary and was subsequently eliminated.
-

-

Provide hospit?dsfkxLbility in how the Messag=
be provided to beneficiaries when they are
unable to receive or understand it. So numy of our Medicare admissions involve patjmts with
dementia who are residing in nursing homes who may not have a family member or r e p d v e
readily available to sign this message. Also, many of these patients require frequent admissions.
Allowing alternative means of communication such as telephone, fix or email would be extremely
beneficial.
Finally, current QIO availabdity for beneficiary appeals is limited to Monday-Friday, daytime hours.
Under the new regulatrons, 2417 availability would be necessary to address beneficiary appeals.
Please clarify the required availability of the QIO to address appeals since the Message is
inconsistent with the QIO manual.
Should you have any questions about these comments, please feel free to contact me at (540) 3324807 or imaneun@,au~ustamed.com.

Sincerely yours,

/ ~ a n a P . Mangun

V

Vice-President, Medical Administration
Cc:

The Honorable John Warner, VA US Senator
The Honorable James Webb, VA US Senator
The Honorable Bob Goodlatte, VA, 6&Congressional District Representative