Comment 2 and 3

MAY-09-2007

15:44

CIMB/'D I R A

202 395 5167

P. 05/38

To: OMB desk officer:
OlMB Human Resources and Housing Branch.

Attention: Carolyn Lovett,

New Executive Office Building, Room 1023 5,
Washington, DC 20503,

Fax Number: (202)395-6974.
From: Jackie Birmingham, RN. MS. CMAC
Vice President of Professional Services/ eDischarge
Curaspan, Inc.
70 Bridge Streef Suite 20 1

Newtos MA 024-58

Phonc (78 1)492-8013

Fax. (860)668-6666

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Date: May 3, 2007
Re: Comments on

Detailed Notice: "CMS-10066".

Dear Ms. Lovett.
Curaspan, Inc. is a privately held company that supports a software progazn called 'eDischarge' that is
used by more than 100 hospitals to streamline and facilitate the discharge of patients to post-acute

providers o f care. In our 8 years experience we are aware that a patient's discharge is not always
predictable, but this does not mean they shouldn't be prepared and informed. We support the

'Notitication of Discharge Appeal Rights' since it directly addresses Medicare Beneficiaries rights to
be informed of the progress oftheir healch care. and in particular their status reyarding discharge from

the hospital
On the followins page are recommendations regardins the Draft of CMS 10066 as published on April
6 , 2007 titled the 'Detailed Notice'.

There are a few minor changes, like the addition of the name ofthe hospital in the heading: Following

is a brief summary of recommended changes in co~zle~rt:
1. Reword of the introductory paragraph that includes a brief explanation of a QIO.
2. Change the wording of sentence in the first bulleted sentence to remove the word 'facts' and add the

phrase 'based on your health condition'

3 . Combined the Medicare and Medicare managed care explanation
4.

Insert a separate and distinct section describing where the patientlrepresentative can get more

information.
a) The QIO should be responsible to give the patient a copy of the information sent to them.
Because hospitals have policies on what information can be given to patients while they

are still hospitalized may make this a very burdensome task. Would the patient have to
sign a release to see a copy of the information sent to the QIO fiorn their own active
medical record?
b) Medicare coverage policies are available to Medicare Beneficiaries in print, on-line and on

the phone. Medicare coverage policies should be communicated to the patient by
Medicare. The patient will likely trust the report of the 'coverage policies' either

directly 5om Medicare or from the Managed care representative if applicable.
c) Hospitals should devote their time and staff to helping patients sort thmugh this process.
5. A final sentence letting the patient know that everyone is advocating for them and that they receive
the best possible and most appropriate care available to them.

Thanlc you for the opportunity to make comment on this very critical document.

222 South Riv8rrido Plaza
C h ' i o , lllinob 60606-6010
MotropO'tbn Ch'cago Tdephone 312-90640m
HePlIkam Council
Faesimllr 312-993-On9

MCMC

May 3,2007

Office of Management and Budget
OM8 Desk Officer
OMB Human Resources and Housing Branch
Attn: Carolyn Lovette
New Executive Office Building, Room 10235
Washington, D. C. 20503
(Fax: 202-395-6974)
RE:

Document Identifier: CMS-10066
Agency Information Collection Activities: Submission for OMB Review; Comment
Request
Published in the ~ e d e r sRegister
l
of April 6 , 2007 (72FR 17169-17170)

I am writing on behalf of the Metropolitan Chicago Healthcare Council, which represents 140
healthcare entities, including more than 100 Illinois hospitals, the majority of which are
located in the eight-county metropolitan Chicago area. We appreciate the opportunity to
provide comments on the above referenced proposed collection of information through a
new "Detailed Notice of Discharge," which will be used by hospitals to provide specific
information that led to a discharge decision to a Medicare beneficiary who appeals a
discharge decision.
Before the "Detailed Notice" is finalized. we recommend that another opportunity for public
comment be offered once CMS has provided specific examples and shared addit~onal
information on proper completion of the form. It is critical mat hospitals be afforded
sufficient time to modify their internal processes to accommodate the new requirements.
We recommend that hospitals be given at least 60 days after the form is finalized and CMS
has issued a Med~caretransmittal with administrative instructions.
Ap~licabilityto Acute Care Setting
The "Detailed Notice of Discharge," as proposed, differs significantly from the current
Hospital Issued Notice of Non-coverage (HINN),which makes a generic statement that
inpatient services are not medically necessary or the patient's condition could be safely
treated in a non-acute setting. The "Detailed Notice" asks the hospital to provide "specific
infonat~onthat describes the current functioning and progress of this patient with resped to
the services being provided," and to provide "the detailed and specific reasons why servlces
are no longer reasonable and necessary or are no longer covered according to Medicare
coverage guidelines." This information is to be presented in full sentences in plain English.
A copy of the Medicare policy is also to be made available upon request.

MA'(-09-2007
U J I U L .

Y Y Y .

16: 00

- - . I -

-

r)t'lB./'r) I PR

202 395 5167

P. 09/'19

A M E R I C A N CASE M A N I G C M E N T A S S O C I A T I O N

To OMB desl; ofticcl*:
OME Hunlai~Resourccs a i d Ho~rsingBraircll,
:\trcl'lr~oir: C ~ r o l ~Lo\:eti.
n
Ne\4' Executive Ot'ricc Hullding. Roo111 10333,
Wdsllington. DC 20503.
Fax X U I I ~ ~ L(202)
' I ' : 595-0074.

Fro111: Donna Ilkvlo\ricz, R3. MS. Prcsidcnt
L. Greg Cunningha~n.MHA. CEO
tln~cricanCasc bla~~agcr~zci~t
Assoclarion (ACMA)
103 10 West Markllaui. Suite 200
Little Rock. A~~kansas
72205
50 1 -007-ACMA ( 2 2 6 2 ) Fax: 501 -327-4247
l~tg~:/~~viv~~~.~~c~~~~~wel~.or~i
.-.

Rc: Co~nnlcntson DctniIcd hoticc: "CMS-10066".

I h c Alncrican Case !vI/lsl~agancnrAssocialion u a proi'cssio~ialorganization 1.eprescntlng hcalth
p~.ofcssionals\rll~owork ti)!-hospitals and hcalth caw systcms. Our 1500 - lnanbers represc~itins
70U6 of rhc I.; .S. gcncrril acutc caw )10spi~dlsaM dedicated nurscs, social u:ori;ers and physicians
\vho nurk \i,i~hMcdicarc. Belleticiarles tll~uuyhthc coursc uf'rhelr I~ospititliz~tion
and ad\-ocau
tiv. thcni during their adlnissioi~.t i . c a ~ n ~and
c r ~disuhwrge
~
process. Wc feel uniqucly qualified to
makc comlnmlt on tlic prclccss ol'the notification o f thc d~schar;;~
~-i_rhtslisr j~atieilts.We sup])ort
this cndeilvor since i t dil-ectly addrcsscd Mctlicarc Bcncjiciaries righrs to bc i i ~ h n n c dof rhc
~ ~ r o p c of
s s their health carc.

On the t i ) l l ~ u ~ iprlgc
~ i y ~1.crcco~~~lnendiltions
fro111 t11c ACM.4 Board of'Directors and the ACMA
Lcgis111ivc:'Aclvocacy Co1311l1ittccon the Draft of CMS 10066 as publisllcd on April 6. 2007
titled the 'Derailed Naticc'. which is part of tllc 'Hospital Discharge Appeal Notices'. Comrncnts
lolltsw cccch section i l l ~ h body
c
of the docume~~t:
Thank yuu for opportunity to subi~litrhcse comments.
I I I-ul-rhcr rxplaiiation 01. clar~tizatioi~
uroirld be hclghl. plcasc Ict us know; I ~ I Cissuc is vcry
i~nportai~t
to our constrrucnts slid their Hospital Ad~ninistra~ors.
ACMA is cotnrniltcd lo giving
ihc lir71c a n d assistance to cnsurc a "Detailed h ~ t i c c "is dcvclopeci tl~aris easily undcrstood and
appl-ol>r-i:~irl
y u t i l ~tecl.