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Notification of Hospital Discharge Appeal Rights (1.2.10)

Notification of Hospital Discharge Appeal Rights (1.2.10) - Policies, Clinical, UW Health Clinical, Administrative, Legally Driven Care, Resources

1.2.10


UW HEALTH CLINICAL POLICY 1
Policy Title: Notification of Hospital Discharge Appeal Rights
Policy Number: 1.2.10
Category: UW Health
Type: Inpatient
Effective Date: February 27, 2017

I. PURPOSE

To implement a process that ensures that Medicare beneficiaries are informed of their rights upon discharge
from a UW Health hospital.

II. POLICY ELEMENTS

A. Initial Notification. All inpatient Medicare beneficiaries must receive and sign a copy of the document written
by the Center for Medicare and Medicare Services ("CMS"), entitled, "An Important Message from Medicare
about your Rights" at or near the time of admission, but no later than two calendar days after admission.
This document informs inpatients of their rights to appeal their discharge from the hospital if they believe
they are being discharged too early.
B. Follow-Up Notification. All inpatient Medicare beneficiaries must receive a signed copy of the "An Important
Message from Medicare about your Rights" document as far in advance as possible, but no more than two
(2) days before discharge.
C. Patients Right to Appeal Discharge. The "An Important Message from Medicare about your Rights"
document informs inpatients about their rights to appeal their discharge. If patients appeal their discharge,
Kepro, Wisconsin’s Quality Improvement Organization (QIO) will conduct an "expedited review" and
determine if the discharge is appropriate. Kepro will contact UW Health to inform us that the patient has
exercised their rights and will let us know what documents they need to review as part of the patient's
hospitalization and determination to discharge.
D. Coverage During Appeal
i. General Rule -- if the beneficiary remains in the hospital past midnight of the date of discharge, and
it is later determined that the beneficiary requires inpatient hospital care, the beneficiary is not
financially responsible for continued care, until UW Health once again determines that the
beneficiary no longer requires inpatient care.
ii. Timely Filing -- if the beneficiary files a timely appeal as required by the "An Important Message
from Medicare" document, the beneficiary is not financially responsible for inpatient hospital
services furnished before noon of the calendar day after the date the beneficiary receives
notification of the expedited determination by Kepro.
iii. Untimely Filing -- if the beneficiary does not file the appeal in time as required by the "An Important
Message from Medicare" document, but remains in the hospital past the discharge date, the
beneficiary may be financially responsible for charges incurred after the date of discharge.
E. Determination of Expedited Review. Kepro’s determination of the appeal is binding on UW Health.

III. PROCEDURE

A. Delivery of Document
i. Admissions staff will provide the patient a copy of the document and obtain the patient's signature
on the initial "An Important Message from Medicare" form. A minimum of two attempts will be made
to deliver this document. The date the signature was captured is noted and a copy of the signed
document is stored in Health Link.
ii. Case management staff will deliver a copy of the signed "An Important Message from Medicare"
document prior to discharge.
B. Patient Exercises Right to Appeal Discharge
i. Kepro will contact the Director of the Coordinated Care Department when a patient chooses to
exercise their right to appeal their discharge.
ii. Coordinated Care Department staff are responsible for making sure the following occurs by noon
the day after being notified by Kepro that a patient has exercised their appeal rights:
a. Provide Kepro with copies of medical and other records requested related to the appeal;
and
b. Ensure that the patient receives a "Detailed Notice of Discharge" document that explains
why they are being discharged. The patient's case manager, social worker, or outcome
manager will most likely prepare and provide the patient with the "Detailed Notice of



UW HEALTH CLINICAL POLICY 2
Policy Title: Notification of Hospital Discharge Appeal Rights
Policy Number: 1.2.10

Discharge" document.
iii. Health Information Management (HIM) staff is also responsible for providing the patient (on
request) with a copy of anything that was submitted to Kepro relating to the appeal. HIM may
charge the patient a reasonable rate for copies of these records.

IV. COORDINATION

Author: Director, UW Health Home Care and Coordinated Care
Senior Management Sponsor: SVP General Counsel
Reviewers: Director, Access Services
Approval committees: UW Health Clinical Policy Committee
UW Health Clinical Policy Committee Approval: January 23, 2017

UW Health is a cohesive, united and integrated academic medical enterprise comprised of several entities.
This policy applies to facilities and programs operated by the University of Wisconsin Hospitals and Clinics
and the University of Wisconsin Medical Foundation, Inc., and to clinical facilities and programs
administered by the University of Wisconsin School of Medicine and Public Health. Each entity is
responsible for enforcement of this policy in relation to the facilities and programs that it operates.

V. APPROVAL

Peter Newcomer, MD
Chief Clinical Officer

J. Scott McMurray, MD
Chair, UW Health Clinical Policy Committee

VI. REFERENCES

CMS Final Rule: CMS-415-F: Notification of Hospital Discharge Appeal Rights
CMS Form: CMS-R-195

VII. REVIEW DETAILS

Version: Revision
Next Revision Due: February 2020
Formerly Known as: Hospital Administrative policy #7.57