Understanding the OBRA Regulatory Framework
Congress passed the Omnibus Budget Reconciliation Act (OBRA) of 1987 to improve the quality of life for residents in long-term care facilities. A key component of OBRA is the Resident Assessment Instrument (RAI), which mandates the use of the Minimum Data Set (MDS). This standardized assessment tool provides a comprehensive clinical picture of each resident's functional, medical, and psychological status. While several types of MDS assessments exist—including admission, annual, and significant change—the discharge assessment is uniquely tied to a resident's transition out of the facility.
There are two types of OBRA discharge assessments: 'return anticipated' and 'return not anticipated.' The distinction hinges on whether the facility expects the resident to come back within a specific timeframe. Getting this correct is paramount for regulatory compliance and ensuring continuity of care. The "return anticipated" assessment is specifically designed for residents whose departure is temporary and whose return is expected within 30 days.
The “Return Anticipated” Scenario Explained
The most common scenario for completing a 'return anticipated' assessment involves a resident leaving the facility for a temporary, short-term absence. These absences typically include a hospital stay, a period of therapeutic leave, or even a brief overnight home visit. The key determinant is the nursing home’s expectation that the resident will be back within 30 days of the discharge date.
Consider the following real-world examples where this assessment is triggered:
- Hospitalization for an Acute Medical Condition: A resident is transported to an acute care hospital for a procedure or an emergency. The medical team and facility staff anticipate the resident will be medically cleared to return to the nursing home. The discharge assessment is completed when they leave the facility, even though they will return later. If the hospital stay extends beyond 30 days, a different assessment process is triggered upon their eventual return.
- Therapeutic Leave: A resident takes a planned leave of absence, such as for a family wedding or a short vacation with relatives. The facility is aware of the planned return date, which falls within the 30-day window.
- Short-term Home Visit: A family member takes a resident home for an overnight visit or a weekend. Again, because the return is planned and within 30 days, a 'return anticipated' discharge is the correct procedure.
The Procedural Aspects of a 'Return Anticipated' Discharge
Properly managing a 'return anticipated' discharge involves specific procedural steps that ensure seamless care coordination and regulatory adherence. The process is not a one-time event but rather a coordinated effort between the resident, their family, and the care team.
- Trigger the Assessment: The assessment begins when the resident physically leaves the facility for a temporary absence with the expectation of returning within 30 days.
- Complete the MDS Discharge Assessment: The facility's clinical team completes the OBRA discharge assessment, indicating the 'return anticipated' status.
- Create an Entry Tracking Record: Upon the resident's return to the facility, an Entry tracking record is required to document their readmission.
- Develop a Robust Discharge Plan: In all discharge scenarios, even temporary ones, robust planning is essential. This includes communicating a clear plan to the resident and their caregiver, detailing things like medications, treatments, and follow-up appointments.
Comparison: Anticipated vs. Not Anticipated Discharges
Understanding the contrast between the two types of discharge assessments is crucial for long-term care staff. The scenarios dictate which type is appropriate.
| Feature | Discharge Return Anticipated | Discharge Return Not Anticipated |
|---|---|---|
| Resident's Status | Temporary discharge from the facility | Permanent or indefinite discharge |
| Expected Return | Anticipated to return within 30 days | No anticipated return to the facility |
| Common Scenarios | Hospital stay, therapeutic leave, short home visit | Permanent move to a new residence, transfer to another facility, or death |
| Assessment Requirement | Requires an MDS discharge assessment at the time of departure and an Entry tracking record upon return | Requires a comprehensive MDS assessment covering the entire stay, completed at the time of discharge |
| Impact on Resident's Bed | Facility may hold the bed for the resident per bed-hold policy | Bed is not held for the resident |
| Post-Discharge Procedure | Focuses on continuity of care and planning for the resident's re-entry | Focuses on the final transition and necessary follow-up care |
The Importance of Accurate Assessment and Planning
Accurately completing the OBRA discharge assessment is not merely a box-ticking exercise for compliance. It directly impacts resident care, facility operations, and regulatory oversight. Correctly identifying a 'return anticipated' scenario ensures that the resident's care plan can be seamlessly reactivated upon their return. This continuity prevents gaps in care, reduces the risk of readmission, and helps maintain the resident's quality of life.
Furthermore, accurate documentation ensures that the facility's records are in line with federal regulations and that billing is correct, especially concerning Medicare. Failure to adhere to these rules can lead to regulatory penalties and a negative impact on the facility's reputation. For caregivers and family members, understanding this assessment provides clarity on the resident's status and ensures they are informed throughout the care transition process.
Conclusion
In summary, the obra discharge assessment return anticipated is a specific and essential regulatory requirement for residents leaving a skilled nursing facility temporarily with a high probability of returning within 30 days. This applies to scenarios like hospital visits, therapeutic leaves, or short home stays. This assessment is critical for both regulatory compliance and providing a coordinated, safe care transition for the resident. By understanding the criteria and procedures, facilities can ensure they meet federal mandates while providing the best possible patient-centered care. For more detailed information, consult authoritative sources such as the official Centers for Medicare & Medicaid Services (CMS) RAI Manual.
