Understanding the OBRA Discharge Assessment
The Omnibus Budget Reconciliation Act of 1987 (OBRA '87) established regulations for nursing facilities participating in Medicare and Medicaid. The Resident Assessment Instrument (RAI), including the Minimum Data Set (MDS), is central to these rules. The OBRA discharge assessment is an MDS assessment documenting a resident’s status upon leaving the facility. This assessment ensures a complete and accurate record for continuity of care, whether the resident goes home, transfers, or moves to a different care level. Proper completion aids in preventing readmissions and meeting post-discharge needs.
When an OBRA Discharge Assessment Is Required
A physical discharge from a nursing facility triggers an OBRA discharge assessment. This includes residents returning home, transferring to another skilled nursing facility (SNF), or moving to assisted living. An assessment is also required if a resident moves from a certified bed to a non-certified bed within the same facility. For residents who pass away in the facility, a separate “Death in Facility” tracking record is used instead of a standard discharge assessment.
Types of OBRA Discharge Assessments
There are two main types of OBRA discharge assessments:
- Discharge Return Not Anticipated (DRNA): Used when it's known the resident won't return within 30 days.
- Discharge Return Anticipated (DRA): Applies when a return within 30 days is expected, such as a temporary hospital transfer. If the resident doesn't return within 30 days, a full Admission assessment is needed upon their reentry.
Specific Timing and Completion Requirements
Accurate timing is crucial. The Assessment Reference Date (ARD) for an OBRA discharge assessment is the resident's last day in the facility (the discharge date). The MDS portion must be completed within 14 days of the ARD, and the completed MDS must be transmitted electronically to CMS within 14 days of completion. If a resident's Medicare Part A stay ends on the same day or one day before their physical discharge, the Part A PPS discharge assessment must be combined with the OBRA discharge assessment, with the ARD set as the discharge date.
The Interdisciplinary Team's Role
The interdisciplinary team collaborates on the OBRA discharge assessment. Each team member contributes to specific MDS sections, with accuracy being vital for a valid assessment.
Comparison: OBRA vs. PPS Discharge Assessments
Understanding the differences between OBRA and PPS discharge assessments is important:
| Feature | OBRA Discharge Assessment | Part A PPS Discharge Assessment |
|---|---|---|
| Triggering Event | Physical discharge from the facility. | End of a resident's Medicare Part A stay. |
| Purpose | Document resident status at discharge for regulatory compliance. | Final payment assessment for Medicare Part A stay. |
| Resident Status | Resident physically leaves the facility. | Resident remains in the facility but is no longer on Medicare Part A. |
| ARD (Assessment Date) | Always the date of discharge. | Last day of the Medicare Part A stay. |
| Combining Assessments | Combined with Part A PPS discharge if Medicare stay ends on or one day before physical discharge. | Combined with an OBRA discharge if Medicare stay ends on or one day before physical discharge. |
Potential Consequences of Non-Compliance
Failure to complete timely and accurate OBRA discharge assessments can lead to survey deficiencies, fines, and penalties from regulatory bodies. It can also result in poor resident outcomes, increased hospital readmissions, and legal liability for the facility due to inadequate discharge planning. Improper timing, especially when assessments are combined with PPS, can also affect Medicare payment.
Proactive Discharge Planning Strategies
Effective discharge planning is crucial. It should start upon admission, not just before discharge. Interdisciplinary team communication is key to accurate discharge plans and assessments. Ongoing resident assessment helps identify changes impacting planning. Using EHR and MDS software can help track due dates and ensure timely transmission of data. Involving residents and families in the planning process is also vital for quality care. Facilities can find more guidance in the {Link: CMS RAI Manual https://www.cms.gov/medicare/quality-initiatives-patient-assessment-instruments/nursinghomequalityinits/mds30raimanual}.
Conclusion
Answering when must an OBRA discharge assessment be completed, the requirement is clear: upon a resident's physical discharge from a long-term care facility, with specific deadlines tied to the discharge date. By understanding the assessment types, timing, and collaborative process, facilities can ensure safe resident transitions with appropriate care plans, promoting healthier aging outcomes.
