LONGITUDINAL COORDINATION OF CARE WORK GROUP – A Community Led Initiative CARE PLAN TERMS & PROPOSED DEFINITIONS December 2012 Care Plan Terms & Proposed Definitions (DRAFT) 1 Table of Contents Introduction ................................................................................................................................ 2 The Importance of a Care Plan .................................................................................................. 2 The Importance of Terms Used to Describe a Care Plan ........................................................... 3 Policy Requirements and the Ambiguous Use of Care Plans and Plans of Care .................... 3 Terms, Structure, and Components of Care Plan to Support Coordination of Care ................ 3 Appendix A: Meaningful Use Requirements for Care Plan ........................................................ 7 Stage 2 Meaningful Use Requirements for Care Plan ............................................................. 7 Future Stages of Meaningful Use ........................................................................................... 7 Appendix B: Physician Fee Schedule Requirements for Coordinating Care .............................10 Medicare Physician Fee Schedule Rule ................................................................................10 Appendix C: CMS Conditions of Participation Requirements for Care Plan ..............................11 Appendix D: CMS Interpretive Guidelines for Care Plan ..........................................................14 Appendix E: References ..........................................................................................................16 S&I Longitudinal Coordination of Care WG December 2012 Care Plan Terms & Proposed Definitions (DRAFT) 2 Introduction The recent Center for Medicare and Medicaid Services (CMS) Meaningful Use Stage 2 Final Rule and calendar year (CY) 2013 Medicare Physician Fee Schedule (MPFS) Final Rule, introduced requirements to exchange care plan content with transitions of care and referrals, and to enhance physician reimbursement for services related to Transitional Care Management. The Standards and Interoperability (S&I) Framework Longitudinal Coordination of Care Workgroup (LCC WG) August 2012 white paper, Meaningful Use Requirements For: Transitions of Care & Care Plans for Medically Complex and/or Functionally Impaired Persons, identified the need for a more robust description of care plan content to be exchanged as part of Meaningful Use requirements and in support of medically complex and/or functionally impaired persons. To further build on these guidelines, the S&I LCC WG has developed the following document, Care Plan Terms & Proposed Definitions, to propose standardized definitions for care plan components in support of the changing dynamics of health care (e.g., Affordable Care Organizations (ACOs), disease management, diverse settings of care). This document describes key terms, structure, and components a care plan to support coordination of care. This document does not define the related processes of a care plan and/or roles and responsibilities associated with those individuals that develop, manage or use a care plan. The Importance of a Care Plan Individuals of all ages are living longer with chronic illness and disability. As the number and complexity of their health conditions increase over time and episodes of acute illness are superimposed, the number of clinicians contributing to the care of these individuals increases as well. It becomes significantly more difficult to align and coordinate care among a growing number of providers in multiple sites. Without a process to reconcile potentially conflicting plans created by multiple providers, it is impossible to avoid unnecessary and potentially harmful interventions. Without such a process, it is also difficult to shift the perspective of clinicians from the management of currently active issues to consideration of future goals and expectations. The Care Plan represents the synthesis and reconciliation of the multiple plans of care produced by each provider to address specific health concerns. It serves as a blueprint shared by all participants to guide the individual’s care. As such, it provides the structure required to coordinate care across multiple sites, providers and episodes of care. S&I Longitudinal Coordination of Care WG December 2012 3 Care Plan Terms & Proposed Definitions (DRAFT) The Importance of Terms Used to Describe a Care Plan The terms “care plan” and “plan of care” appear to be used interchangeably within and among policy statements. Neither term is used precisely enough to convey the difference between a treatment plan for a specific condition, a plan of care proposed by an individual clinician to address several conditions or a care plan that integrates multiple interventions proposed by multiple providers for multiple conditions. The management of medically complex and/or functionally impaired individuals requires all of these different types of plans. In order for these individuals to receive the care they need, policy statements should reflect the precision required to provide complex care. Policy Requirements and the Ambiguous Use of Care Plans and Plans of Care There are several policy provisions that require providers to establish “care plans”, “plans of treatment” and “plans of care” including: CMS Conditions of Participation, Conditions of Participation: Home Health Agencies.( § 484.18(a)) CMS Requirements for States and Long Term Care Facilities (§ 483.20 (k)) CMS Conditions of Participation for Hospitals (§ 482.61(c)) JCAHO Ambulatory Accreditation Program (RC.02.01.01) These concepts are not defined in these regulations but appear to be used synonymously and sometimes interchangeably across and even within various regulatory requirements. More recent policy requirements that have emerged which underscore both the importance of “care plan” for medically complex /functionally impaired persons and the need to unambiguously define these terms are listed in table 1. Within these regulations, the term ‘care plan’ and its components are not defined in a clear and precise manner. Table 1: Policy Requirements With Ambiguous Care Plan Terminology Regulation MU Stage 2 Final Rule CY2013 Medicare Physician Fee Schedule Final Rule Request for Comment – Meaningful Use Stage 3 Brief Description Care plan content, if known, is required in the summary of care for each transition of care or referral Included payment provisions for Transitional Care Management (TCM) and recognized the need for communication and coordination across providers at transitions of care Proposes to build on Stage 2 care plan requirements for MU Stage 3 and future stages Terms, Structure, and Components of Care Plan to Support Coordination of Care With the increased focus on communication and coordination of care across providers, settings and time, the need for clear, unambiguous terms to express the structure and components S&I Longitudinal Coordination of Care WG December 2012 Care Plan Terms & Proposed Definitions (DRAFT) 4 needed to plan and coordinate care becomes critical. The LCC WG has developed this Care Plan Terms & Proposed Definitions document to catalog key terms and concepts so that it may serve as a vehicle to gather input toward consensus on the semantics, structure, and components of this foundational activity. As part of it’s scope of work under the S&I Framework, the LCC WG has developed a set of data elements that the WG believes are required to create and exchange a “Care Plan” (CP) for medically complex and functionally impaired individuals1. To better normalize these data elements across healthcare settings and scenarios, the WG is proposing a set of definitions to help frame these data elements. These proposals comprise two small steps towards the development of an unambiguous and shared view of the complex processes involved in aligning the interventions required to meet the health concerns of these individuals. The ultimate goal is to identify the information that is required for the exchange of a CP and standardize the content, format and definitions of that information to support its interoperable exchange across all relevant sites and to all involved parties. The inability to create and exchange a CP is a growing problem. As our population ages and accumulates chronic conditions, there is an increase in the number and types of interventions required to address acute illness and to restore and maintain health and function. These interventions involve more participants and more sites of care putting a premium on communication and integration. As complexity increases so does the requirement to align interventions across multiple sites and participants in order to avoid gaps in care, duplicate or conflicting interventions, and deviation from the individual’s goals of care. In parallel, healthcare payment models that put a premium on coordination of care across multiple sites and providers are evolving. This is especially true for patients with complex medical and functional needs who make up approximately 10% of patients and account for 70% of health care expenditures. For these individuals, the CP provides the blueprint for aligning interventions to improve quality and efficiency of care. Most individuals—the other 90%--do not require this level of coordination or communication to receive efficient, high quality care. They receive most of their care from one clinician or one team and their plan of care is coordinated among team members including one or more of a small group of collaborating providers and the patient. Individuals with more than one significant health problem may have specific care teams dedicated to their management. Currently, there are many different processes in place that create effective integrated CPs for different subgroups of complex individuals (e.g., PACE, Hospice, etc.). Depending on the complexity of the patient and the numbers of clinical disciplines involved and the patient’s preferences, it may be necessary to reconcile and align care plans across disciplines. The following table lists LCC WG proposed definitions for key ‘care plan’ terms and components. For comparison, applicable terminologies from the Meaningful Use (MU) stage 2 rule are provided. 1 The S&I LTPAC Sub-workgroup has identified over 480 unique data elements for LTPAC information exchange. The final list is available at: http://wiki.siframework.org/file/view/IMPACT%20Transfer%20of%20Care%20Dataset%2010-20-12%20%20For%20Distribution.xls/375236566/IMPACT%20Transfer%20of%20Care%20Dataset%2010-20-12%20%20For%20Distribution.xls S&I Longitudinal Coordination of Care WG December 2012 Care Plan Terms & Proposed Definitions (DRAFT) 5 Further information on the stage 2 requirements for care plan and future stages for MU are provided in Appendix A. Appendix B lists the Physician Fee Schedule requirements for coordinating care, Appendix C outlines the CMS conditions of participation requirements for Care Plan and Appendix D provides the CMS Interpretive Guidelines for Care Plan. Table 2: LCC WG Proposed Definitions for Care Plan Terms/ Components Term/Component MU2 LCC Proposed Definition CARE PLAN Not defined The S&I LCC believes that the exchange of care plans is important to support collaboration across care settings and providers, and allows for and can encourage team based care. The S&I LCC believes that a “care plan” considers the whole person and focuses on a number of health concerns to achieve high level goals related to healthy living. In contrast, some clinicians use the concept of “plan of care” to focus on discrete problems, the specific interventions to address the problem, and achieve a certain goal related to the problem. Term/Component MU2 LCC Proposed Definition The S&I LCC WG believes that both the Care Plan and Plan of Care share the universal components: health concern, goals, instructions, interventions, and team member. HEALTH CONCERN Health concern is not defined. “Problem” is defined as “The focus of the care plan” Health concerns reflect the issues, current status and 'likely course' identified by the patient or team members that require intervention(s) to achieve the patient's goals of care, any issue of concern to the individual or team member. “Problems” and “diagnoses” will capture medical/surgical diagnosis but are insufficient to capture the full array of issues that are important to individuals. Health concerns include: Medical/surgical diagnoses and severity Nursing/Allied Health/Behavioral Health issues Patient reported health concerns Behavioral/Cognition/Mood issues Functional status, including ADL issues Environmental factors (e.g. housing and transportation) Social factors including availability of support and relationships Financial issues (e.g. insurance, eligibility for disability) S&I Longitudinal Coordination of Care WG December 2012 Care Plan Terms & Proposed Definitions (DRAFT) Term/Component MU2 LCC Proposed Definition Term/Component MU2 LCC Proposed Definition Term/Component MU2 LCC Proposed Definition Term/Component MU2 LCC Proposed Definition Term/Component MU2 LCC Proposed Definition 6 GOALS The target outcome; target or measure to be achieved in the process of patient care (an expected outcome). A defined outcome or condition to be achieved in the process of patient care. Includes patient defined goals (e.g., prioritization of health concerns, interventions, longevity, function, comfort) and clinician specific goals to achieve desired and agreed upon outcomes. INSTRUCTIONS “By clinical instructions we mean care instructions for the patient that are specific to the office visit. Although we recognize that these clinical instructions at times may be identical to the instructions included as part of the care plan, we also believe that care plans may include additional instructions that are meant to address long-term or chronic care issues, whereas clinical instructions specific to the office visit may be related to acute patient care issues. Therefore, we maintain these as separate items in the list of required elements later.” Information or directions to the patient and other providers including how to care for the individual’s condition, what to do at home, when to call for help, any additional appointments, testing, and changes to the medication list or medication instructions, clinical guidelines and a summary of best practice. Detailed list of actions required to achieve the patient's goals of care. INTERVENTIONS Not defined Actions taken to maximize the prospects of achieving the patient's or providers' goals of care, including the removal of barriers to success. Instructions are a subset of interventions. OUTCOMES Target outcome; target or measure to be achieved in the process of patient care (an expected outcome). Status, at one or more points in time in the future, related to established care plan goals. TEAM MEMBER Care team includes the primary care provider of record and any additional known care team members beyond the referring or transitioning provider and the receiving provider. Parties who manage and/or provide care or service as specified and agreed to in the care plan, including: clinicians, other paid and informal caregivers, and the patient. S&I Longitudinal Coordination of Care WG December 2012 7 Care Plan Terms & Proposed Definitions (DRAFT) Appendix A: Meaningful Use Requirements for Care Plan Stage 2 Meaningful Use Requirements for Care Plan In support of the national health outcomes policy priority to improve care coordination, the MU Stage 2 Final Rule established objectives requiring the EP or EH/CAH who” transitions their patient to another setting of care or provider of care, or refers their patient to another provider of care, provides a summary care record for each transition of care or referral” and set measures requiring this information exchange to occur for more than 50% of these transactions (page 54047). The rule also specifies data elements that, if known, are to be included in the summary of care. New for MU Stage 2 is the inclusion of the following care plan content among the data elements required in the summary of care: Care plan field, including goals and instructions. Care team including the primary care provider of record and any additional known care team members beyond the referring or transitioning provider and the receiving provider (page 54016). The MU Stage 2 Final Rule also provided the following definition of “care plan”: For purposes of the clinical summary, we define a care plan as the structure used to define the management actions for the various s conditions, problems, or issues. A care plan must include at a minimum the following components: problem (the focus of the care plan), goal (the target outcome) and any instructions that the provider has given to the patient. A goal is a defined target or measure to be achieved in the process of patient care (an expected outcome) (page 54001). The MU2 requirements do not adequately define the concept of care plan nor its component parts. Future Stages of Meaningful Use Proposals for future stages of Meaningful Use, presented in the November 2012 Health IT Policy Committee (HITPC) request for comments (RFC) regarding the Stage 3 definition of meaningful use of EHRs, expand on the care plan requirements described above and include: ID# SGRP 303 (MU Stage 3) EP/ EH / CAH Objective: EP/EH/CAH who transitions their patient to another setting of care or refers their patient to another provider of care Provide a summary of care record for each site transition or referral when transition or referral occurs with available information Must include the following four for transitions of site of care, and the first for referrals (with the others as clinically relevant): 1. Concise narrative in support of care transitions (free text that captures current care synopsis S&I Longitudinal Coordination of Care WG December 2012 8 Care Plan Terms & Proposed Definitions (DRAFT) and expectations for transitions and / or referral) 2. Setting-specific goals 3. Instructions for care during transition and for 48 hours afterwards 4. Care team members, including primary care provider and caregiver name, role and contact info (using DECAF) Measure: The EP, eligible hospital, or CAH that site transitions or refers their patient to another setting of care (including home) or provider of care provides a summary of care record for 65% of transitions of care and referrals (and at least 30% electronically). Certification Criteria: EHR is able to set aside a concise narrative section in the summary of care document that allows the provider to prioritize clinically relevant information such as reason for transition and/or referral. Certification Criteria: Inclusion of data sets being defined by S&I Longitudinal Coordination of Care WG, which and are expected to complete HL7 balloting for inclusion in the C-CDA by Summer 2013: 1. Consultation Request (Referral to a consultant or the ED) 2. Transfer of Care (Permanent or long-term transfer to a different facility, different care team, or Home Health Agency) Questions/Comments: *What would be an appropriate increase in the electronic threshold based upon evidence and experience? ID# SGRP 304 (Undetermined Stage) EP/ EH / CAH Objective: EP/ EH/CAH who transitions their patient to another site of care or refers their patient to another provider of care. For each transition of site of care, provide the care plan information, including the following elements as applicable: •Medical diagnoses and stages •Functional status, including ADLs •Relevant social and financial information (free text) •Relevant environmental factors impacting patient’s health (free text) •Most likely course of illness or condition, in broad terms (free text) •Cross-setting care team member list, including the primary contact from each active provider setting, including primary care, relevant specialists, and caregiver •The patient’s long-term goal(s) for care, including time frame (not specific to setting) and initial steps toward meeting these goals •Specific advance care plan (POLST) and the care setting in which it was executed For each referral, provide a care plan if one exists Measure: The EP, eligible hospital, or CAH that transitions or refers their patient to another site of care or provider of care provides the electronic care plan information for 10% of transitions of care to receiving provider and patient/caregiver. Certification Criteria: Develop standards for a shared care plan, as being defined by S&I Longitudinal Coordination of Care WG. Some of the data elements in the shared care plan overlap content represented in the CDA. Adopt standards for the structured recording of other S&I Longitudinal Coordination of Care WG December 2012 9 Care Plan Terms & Proposed Definitions (DRAFT) data elements, such as patient goals and related interventions. Questions/Comments: 1. How might we advance the concept of an electronic shared care planning and collaboration tool that crosses care settings and providers, allows for and encourages team based care, and includes the patient and their non-professional caregivers? Interested in experience to date and the lessons learned. Think through these priority use cases: o Patient going home from an acute care hospital admission o Patient in nursing home going to ED for emergency assessment and returning to nursing home o Patient seeing multiple ambulatory specialists needing care coordination with primary care o Patient going home from either hospital and / or nursing some and receiving home health services 2. What are the most essential data elements to ensuring safe, effective care transitions and ongoing care management? How might sharing key data elements actually improve the communication? Consider health concerns, patient goals, expected outcomes, interventions, including advance orders, and care team members. What data strategy and terminology are required such that the data populated by venue specific EHRs can be exchanged. How might existing terminologies be reconciled? 3. What are the requirements (legal, workflow, other considerations) for patients and their identified team to participate in a shared care plan? Is it useful to consider role-based access as a technical method of implementing who will have access to and be able to contribute to the care plan? How will such access be managed? S&I Longitudinal Coordination of Care WG December 2012 Care Plan Terms & Proposed Definitions (DRAFT) 10 Appendix B: Physician Fee Schedule Requirements for Coordinating Care Medicare Physician Fee Schedule Rule The calendar year (CY) 2013 Medicare Physician Fee Schedule Final Rule included payment provisions for Transitional Care Management (TCM). It recognizes the need for communication and coordination across providers at transitions of care. The TCM codes cover face-to-face and non-face-to-face post discharge services such as communication with the patient, caregiver, home health agency or other community services; education to support self-management, independent living, and activities of daily living; identification of available community and health resources; obtaining and reviewing discharge information, reviewing need for or follow-up on pending diagnostic tests and treatments; establishing referrals and arranging community resources; etc. S&I Longitudinal Coordination of Care WG December 2012 11 Care Plan Terms & Proposed Definitions (DRAFT) Appendix C: CMS Conditions of Participation Requirements for Care Plan Title 42 - Public Health. - . SUBCHAPTER E - STANDARDS AND CERTIFICATION. PART 484 - CONDITIONS OF PARTICIPATION: HOME HEALTH AGENCIES. Subpart B - Administration. § 484.18 Condition of participation: Acceptance of patients, plan of care, and medical supervision. Patients are accepted for treatment on the basis of a reasonable expectation that the patient's medical, nursing, and social needs can be met adequately by the agency in the patient's place of residence. Care follows a written plan of care established and periodically reviewed by a doctor of medicine, osteopathy, or podiatric medicine. (a) Standard: Plan of care. The plan of care developed in consultation with the agency staff covers all pertinent diagnoses, including mental status, types of services and equipment required, frequency of visits, prognosis, rehabilitation potential, functional limitations, activities permitted, nutritional requirements, medications and treatments, any safety measures to protect against injury, instructions for timely discharge or referral, and any other appropriate items. If a physician refers a patient under a plan of care that cannot be completed until after an evaluation visit, the physician is consulted to approve additions or modifications to the original plan. Orders for therapy services include the specific procedures and modalities to be used and the amount, frequency, and duration. The therapist and other agency personnel participate in developing the plan of care. (b) Standard: Periodic review of plan of care. The total plan of care is reviewed by the attending physician and HHA personnel as often as the severity of the patient's condition requires, but at least once every 62 days. Agency professional staff promptly alert the physician to any changes that suggest a need to alter the plan of care. (c) Standard: Conformance with physician orders. Drugs and treatments are administered by agency staff only as ordered by the physician. Verbal orders are put in writing and signed and dated with the date of receipt by the registered nurse or qualified therapist (as defined in § 484.4 of this chapter) responsible for furnishing or supervising the ordered services. Verbal orders are only accepted by personnel authorized to do so by applicable State and Federal laws and regulations as well as by the HHA's internal policies. [54 FR 33367, August 14, 1989, as amended at 56 FR 32974, July 18, 1991; 64 FR 3784, Jan. 25, 1999] Title 42 - Public Health. - . SUBCHAPTER E - STANDARDS AND CERTIFICATION. PART 483 - REQUIREMENTS FOR STATES AND LONG TERM CARE FACILITIES. Subpart B - Requirements for Long Term Care Facilities. § 483.20 Resident Assessment (k) Comprehensive care plans. (1) The facility must develop a comprehensive care plan for each resident that includes measurable objectives and timetables to meet a resident's medical, nursing, and mental and psychosocial needs that are identified in the comprehensive assessment. The care plan must describer the following— (i) The services that are to be furnished to attain or maintain the resident's highest practicable physical, mental, and psychosocial well-being as required under § 483.25; and (ii) Any services that would otherwise be required under § 483.25 but are not provided due to the resident's exercise of rights under § 483.10, including the right to refuse treatment under § 483.10(b)(4). S&I Longitudinal Coordination of Care WG December 2012 12 Care Plan Terms & Proposed Definitions (DRAFT) (2) A comprehensive care plan must be— (i) Developed within 7 days after completion of the comprehensive assessment; (ii) Prepared by an interdisciplinary team, that includes the attending physician, a registered nurse with responsibility for the resident, and other appropriate staff in disciplines as determined by the resident's needs, and, to the extent practicable, the participation of the resident, the resident's family or the resident's legal representative; and (iii) Periodically reviewed and revised by a team of qualified persons after each assessment. (3) The services provided or arranged by the facility must— (i) Meet professional standards of quality; and (ii) Be provided by qualified persons in accordance with each resident's written plan of care. Title 42 - Public Health. - . SUBCHAPTER E - STANDARDS AND CERTIFICATION. PART 482 - CONDITIONS OF PARTICIPATION FOR HOSPITALS. Subpart E - Requirements for Specialty Hospitals. § 482.61 Condition of participation: Special medical record requirements for psychiatric hospitals. (c) Standard: Treatment plan. (1) Each patient must have an individual comprehensive treatment plan that must be based on an inventory of the patient's strengths and disabilities. The written plan must include— (i) A substantiated diagnosis; (ii) Short-term and long-range goals; (iii) The specific treatment modalities utilized; (iv) The responsibilities of each member of the treatment team; and (v) Adequate documentation to justify the diagnosis and the treatment and rehabilitation activities carried out. (2) The treatment received by the patient must be documented in such a way to assure that all active therapeutic efforts are included. Title 42 - Public Health. - . SUBCHAPTER E - STANDARDS AND CERTIFICATION. PART 485 - CONDITIONS OF PARTICIPATION: SPECIALIZED PROVIDERS. Subpart B - Conditions of Participation: Comprehensive Outpatient Rehabilitation Facilities. § 485.60 Condition of participation: Clinical records (a) Standard: Content. . . . (2) Current plan of treatment; Title 42 - Public Health. - . SUBCHAPTER E - STANDARDS AND CERTIFICATION. PART 485 - CONDITIONS OF PARTICIPATION: SPECIALIZED PROVIDERS. Subpart H—Conditions of Participation for Clinics, Rehabilitation Agencies, and Public Health Agencies as Providers of Outpatient Physical Therapy and Speech-Language Pathology Services § 485.711 Condition of participation: Plan of care and physician involvement. For each patient in need of outpatient physical therapy or speech pathology services there is a written plan of care established and periodically reviewed by a physician, or by a physical therapist or speech pathologist respectively. The organization has a physician available to furnish necessary medical care in case of emergency. ... (b) Standard: Plan of care. (1) For each patient there is a written plan of care established by the physician or by the physical S&I Longitudinal Coordination of Care WG December 2012 Care Plan Terms & Proposed Definitions (DRAFT) 13 therapist or speech-language pathologist who furnishes the services. (2) The plan of care for physical therapy or speech pathology services indicates anticipated goals and specifies for those services the— (i) Type; (ii) Amount; (iii) Frequency; and (iv) Duration. (3) The plan of care and results of treatment are reviewed by the physician or by the individual who established the plan at least as often as the patient's condition requires, and the indicated action is taken. (For Medicare patients, the plan must be reviewed by a physician, nurse practitioner, clinical nurse specialist, or physician assistant at least every 30 days, in accordance with § 410.61(e) of this chapter.) (4) Changes in the plan of care are noted in the clinical record. If the patient has an attending physician, the therapist or speech-language pathologist who furnishes the services promptly notifies him or her of any change in the patient's condition or in the plan of care. Title 42 - Public Health. - . SUBCHAPTER E - STANDARDS AND CERTIFICATION. PART 486 - CONDITIONS FOR COVERAGE OF SPECIALIZED SERVICES FURNISHED BY SUPPLIERS Subpart D—Conditions for Coverage: Outpatient Physical Therapy Services Furnished by Physical Therapists in Independent Practice § 486.155 Condition for coverage: Plan of care For each patient, a written plan of care is established and periodically reviewed by the individual who established it. ... (b) Standard: Plan of care. (1) For each patient there is a written plan of care that is established by the physician or by the physical therapist who furnishes the services. (2) The plan indicates anticipated goals and specifies for physical therapy services the— (i) Type; (ii) Amount; (iii) Frequency; and (iv) Duration. (3) The plan of care and results of treatment are reviewed by the physician or by the therapist at least as often as the patient's condition requires, and the indicated action is taken. (4) Changes in the plan of care are noted in the clinical record. If the patient has an attending physician, the therapist who furnishes the services promptly notifies him or her of any change in the patient's condition or in the plan of care. (For Medicare patients, the plan must be reviewed by a physician in accordance with § 410.61(e).) S&I Longitudinal Coordination of Care WG December 2012 Care Plan Terms & Proposed Definitions (DRAFT) 14 Appendix D: CMS Interpretive Guidelines for Care Plan State Operations Manual Appendix B - Guidance to Surveyors: Home Health Agencies §484.18(a) Standard: Plan of Care G159 The plan of care developed in consultation with the agency staff covers all pertinent diagnoses, including mental status, types of services and equipment required, frequency of visits, prognosis, rehabilitation potential, functional limitations, activities permitted, nutritional requirements, medications and treatments, any safety measures to protect against injury, instructions for timely discharge or referral, and any other appropriate items. G162 (Rev. 11, Issued: 08-12-05; Effective/Implementation: 08-12-05) The therapist and other agency personnel participate in developing the plan of care. Interpretive Guidelines §484.18(a) A statutory change renamed the “plan of treatment” to “the plan of care.” These terms are synonymous. Neither is to be confused with a nursing care plan. The conditions do not require an HHA to either develop or maintain a nursing care plan as opposed to a medical plan of care. This does not preclude an HHA from using nursing care plans if it believes that such plans strengthen patient care management, the organization and delivery of services, and the ability to evaluate patient outcomes. ... Written HHA policies and procedures should specify that all clinical services are implemented only in accordance with a plan of care established by a physician’s written orders. ... The plan of care must be established and authorized in writing by the physician based on an evaluation of the patient’s immediate and long term needs. The HHA staff, and if appropriate, other professional personnel, shall have a substantial role in assessing patient needs, consulting with the physician, and helping to develop the overall plan of care. ... The patient has the right, and should be encouraged, to participate in the development of the plan of care before care is started and when changes in the established plan of care are implemented. "Care Plan" Pg. 75 - "When corrections are made to an assessment already submitted to the state system, the HHA must determine if there is an impact on the patient’s current care plan." Pg. 91 - "Drugs and treatments ordered by the patient’s physician and not documented on the care plan should be recorded in the clinical record." State Operations Manual Appendix PP - Guidance to Surveyors for Long Term Care Facilities F279 §483.20(k) Comprehensive Care Plans (1) The facility must develop a comprehensive care plan for each resident that includes measurable objectives and timetables to meet a resident’s medical, nursing, and mental and psychosocial needs that are identified in the comprehensive assessment. The care plan must describe the following: (i) The services that are to be furnished to attain or maintain the resident’s highest practicable physical, mental, and psychosocial well-being as required under §483.25; and S&I Longitudinal Coordination of Care WG December 2012 Care Plan Terms & Proposed Definitions (DRAFT) 15 (ii) Any services that would otherwise be required under §483.25 but are not provided due to the resident’s exercise of rights under §483.10, including the right to refuse treatment under §483.10(b)(4). Interpretive Guidelines §483.20(k): An interdisciplinary team, in conjunction with the resident, resident’s family, surrogate, or representative, as appropriate, should develop quantifiable objectives for the highest level of functioning the resident may be expected to attain, based on the comprehensive assessment. ... The care plan must reflect intermediate steps for each outcome objective if identification of those steps will enhance the resident’s ability to meet his/her objectives. Facility staff will use these objectives to monitor resident progress. Facilities may, for some residents, need to prioritize their care plan interventions. This should be noted in the clinical record or on the plan or care. F280 ... §483.20(k)(2) A comprehensive care plan must be-(i) Developed within 7 days after the completion of the comprehensive assessment; (ii) Prepared by an interdisciplinary team, that includes the attending physician, a registered nurse with responsibility for the resident, and other appropriate staff in disciplines as determined by the resident’s needs, and, to the extent practicable, the participation of the resident, the resident’s family or the resident’s legal representative; and (iii) Periodically reviewed and revised by a team of qualified persons after each assessment. Interpretive Guidelines §483.20(k)(2): As used in this requirement, “Interdisciplinary” means that professional disciplines, as appropriate, will work together to provide the greatest benefit to the resident. It does not mean that every goal must have an interdisciplinary approach. The mechanics of how the interdisciplinary team meets its responsibilities in developing an interdisciplinary care plan (e.g., a face-to-face meeting, teleconference, written communication) is at the discretion of the facility. ... "Plan of Care" Pg. 34 - "The resident has the right to . . . Perform services for the facility, if he or she chooses, when--(i) The facility has documented the need or desire for work in the plan of care;" Pg. 60 - "Also determine if the plan of care was consistently implemented." Pg. 84 - "This information should be noted in the assessment and identified in the plan of care." Pg. 94 - "Observe during various shifts in order to determine if staff are consistently implementing those portions of the comprehensive plan of care related to activities." Pg. 99 - "If care plan concerns are noted, interview staff responsible for care planning regarding the rationale for the current plan of care." S&I Longitudinal Coordination of Care WG December 2012 Care Plan Terms & Proposed Definitions (DRAFT) 16 Appendix E: References Medicare and Medicaid Programs; Electronic Health Record Incentive Program—Stage 2; Health Information Technology: Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology, 2014 Edition; Revisions to the Permanent Certification Program for Health Information Technology; Final Rules, 77 Fed. Reg. (2012) (to be codified at 42 C.F.R. Parts 412, 413, and 495) Add CMS Online Manuals for CoP and Interpretive Guidelines S&I Longitudinal Coordination of Care WG December 2012