Corporate Compliance

Dialysis and discharge

Compliance Monitor, April 15, 2005

Q: In a recent audit of our hemodialysis procedures, I discovered that almost 14% of our hemodialysis patients receive a treatment on their date of discharge. We use a contractor to perform our dialysis procedures and do not have any in-house staff trained for dialysis. My CFO and audit committee want me to verify that other hospitals that have a contractor relationship for their dialysis procedures are seeing the same rate of dialysis on discharge date. Their question involves whether the patient should be discharged and then treated at a dialysis clinic, or if the physicians are taking advantage of our situation to avoid the loss they would take due to low reimbursement rates for the procedure.

A: If the patient is stable before hemodialysis and can clearly be discharged without danger, then he or she should be discharged with instructions to go to his/her usual hemodialysis center.

The only way Medicare will pay for the hemodialysis if you are not a hemodialysis provider is if it is provided on an emergency basis.

The situation you are describing does not sound like it would qualify as an emergency. If the patient is not stable, you still need to provide the treatment for malpractice reasons. We have the same problem sometimes. We strongly encourage the physicians to discharge for outpatient dialysis in situations that do not affect patient safety.

This question was answered by Marianne Labahn MS, RN, CHC, director of corporate compliance, Cancer Treatment Centers of America.

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