The COVID-19 Public Health Emergency (PHE) officially ended on May 11, 2023, and with it over 3 years of the extraordinary regulatory waivers that Medicare put in place to give healthcare providers the flexibility needed to respond to the pandemic. Although the PHE is over, much has permanently changed in the American healthcare landscape and many of those changes directly impact the current and future role of hospital case management.
First and foremost, many leaders in case management will recall that just prior to COVID-19, CMS made significant changes to the Medicare Discharge Planning Regulations as part of the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act). These rules were only in effect for a few months before the PHE provided blanket waivers for discharge planning as well as the 3-day hospital stay SNF waiver, so it’s likely that many health systems never fully implemented policies and procedures to ensure compliance with the new regulations.
Repisodic has already covered many of these details in a previous article, but in summary these are the most important waivers that ended with the PHE impacting case management:
Limit Discharge Planning for Hospitals
After the expiration of the PHE, hospitals must again assist patients, their families, or the patient’s representative in selecting a post-acute care provider by using and sharing data that includes, but is not limited to, home health agency (HHA), skilled nursing facility (SNF), inpatient rehabilitation facility (IRF), and long-term care hospital (LTCH) data on quality measures and data on resource use measures. These hospital types must ensure that the post-acute care data on quality measures and data on resource use measures is relevant and applicable to the patient’s goals of care and treatment preferences.
Modify Discharge Planning for Hospitals
Medicare was waiving certain, more detailed, requirements related to hospital discharge planning for post-acute care services at 42 CFR §482.43(c), so as to expedite the safe discharge and movement of patients among care settings, and to be responsive to fluid situations in various areas of the country. CMS is no longer waiving certain requirements for those patients discharged home and referred for HHA services, or for those patients transferred to a SNF for post-hospital extended care services, or transferred to an IRF or LTCH for specialized hospital services. For example, a patient may not be able to receive a comprehensive list of nursing homes in the geographic area, but must still be discharged to a nursing home that is available to provide the care that is needed by the patient.
3-Day Skilled Nursing Facility (SNF) waiver
During the pandemic, Medicare temporarily waived the requirement for a 3-day prior hospitalization before covering the cost for a skilled nursing facility (SNF). However now that the PHE is over, patients who get referred to a SNF without 3 days in the hospital will either be denied admission to the SNF or may be surprised by an unexpected bill when Medicare won’t cover it.
What Else is Changing?
The end of the PHE is not just limited to straightforward regulatory changes and the end the certain Medicare waivers. The Covid-19 pandemic fundamentally challenged and changed the American health system, showing not just severe gaps and limitations in the care continuum but also tremendous opportunity, especially in case management. There is a new willingness among traditionally conservative and slow moving organizations to more quickly embrace new technology and a new way of doing things, with virtual care and tele-health being the most obvious example. So as the situation continues to improve and healthcare returns to this new normal, the team at Repisodic took some time to reflect with our health system partners on what case management looks like in a post-pandemic landscape. Below are some of our key takeaways:
Staffing Challenges along the Care Continuum
Staffing is and will continue to be one of the top challenges in healthcare for the indefinite future, and case management as well as post-acute care is no exception. Large numbers of healthcare workers left the workforce during Covid; and there are simply not enough workers or those in the educational pipeline to replace them. This is true for hospital case managers but the situation is even worse in the post-acute setting, where staffing especially for skilled nursing care and home health continues to create capacity issues.
Patient Complexity in the Post-Acute Care Setting
As hospitals tried to free up space during Covid, the outcome was that sicker patients were being discharged into the post-acute setting for follow-up care. Hospitals are now realizing that more clinically complex patients can be successfully discharged to a community setting without additional risk to outcomes, and with lesser costs we expect this trend to continue.
Technology, Automation and the Rise of AI
Yes, even case management is not immune to the suddenly everywhereness of AI. In truth though, technology adoption in case management and post-acute care was on the rise prior to Covid and even though it stalled during the pandemic due to resources focused on the pandemic, it has become more important than even post-Covid. The pandemic showed the sometimes overlooked but critical role of case managers for patient flow, and now health systems are recognizing the need to invest in technology enablement for those departments. Automation is especially valuable where so much of the discharge workflow is repeatable non-value add work that can be powered by technology and AI learning models.
Remote Work and Virtual Case Management
Also related to the staffing and technology categories above, the pandemic showed that to some extent, remote work and virtual case management is a viable model in the right situations. While there will always be a need for in-person case managers to handle patient transitions of care, some parts of the workflow, such as utilization management, prior authorizations, or even discharge planning can be done remotely. And with the proper use of technology, a virtual case management staffing model can be highly successful and cost effective.
These are just some of the forward looking trends that can be attributed to case management in a post-pandemic landscape. As horrible as the Covid pandemic was for so many Americans and the shortcomings it highlighted in our healthcare system, it did show that we do have an amazing ability to adapt quickly when necessary. The learnings from Covid will take a long time for the industry to digest, but we believe that the above shows we are already taking learnings from the pandemic and turning into positive actions.
At Repisodic, we are dedicated to working hand in hand with our healthcare partners across the care continuum, from hospitals to post-acute care providers, to help them understand, navigate and succeed in the post-pandemic landscape. With technology that automates patient discharges and improves patient care transitions for all stakeholders, we are preparing case management leaders across the country for a better future in American healthcare.
Want to learn more about how we are helping to power the future of case management? Get in touch with us today!
