Transcript Slide 1
CMS HOSPITAL CONDITIONS OF
PARTICIPATION (COPS) 2013
What PPS Hospitals Need to Know
About the UR and Discharge Planning Standards
Speaker
Sue Dill Calloway RN, Esq
AD, BA, BSN, MSN, JD CPHRM
President of Patient Safety and
Health Care Consulting
Past Chief Learning Officer
Emergency Medicine Foundation
www.empsf.org
Dublin, Ohio 43017
614 791-1468
[email protected]
2
The Conditions of Participation CoP
Regulations first published in 1986 with the
current version published December 22, 2011
CMS made more than 2 dozen changes to the
CMS CoP as published in the Federal Register on
May 16, 2012 and effective July 16, 2012
None effected the UR/Discharge Planning
standards
First published in the Federal Register and
then CMS published Interpretive Guidelines
and some of the standards have a survey
procedure which is direction to the surveyors
3
The Conditions of Participation
Good way to keep up is sign up for the Federal Register
1
Hospitals should check the survey and certification
website once a month for changes 2
Another good place to check monthly is the transmittal
website 3
Things are published in a transmittal before being added to
the CMS CoP manual
Have one person assigned to check these once a
month
1 www.gpoaccess.gov/fr/index.html
2 www.cms.hhs.gov/SurveyCertificationGenInfo/PMSR/list.asp
3 www.cms.gov/Transmittals/01_overview.asp
4
CMS Survey and Certification Website
www.cms.gov/SurveyCertificat
ionGenInfo/PMSR/list.asp#To
pOfPage
5
CMS Transmittals
www.cms.gov/Transmittals/01_overview.asp
6
TJC Revised Requirements
TJC hospital manual has many changes
Brought their standards into closer
compliance with the CMS CoP and many
R&S changes
Different standards for those who use TJC
for deemed status and those who do not
Example: VA Hospitals do not use TJC for
deemed status since they do not apply for
Medicaid or Medicare
7
TJC Standard Changes
LD.04.01.01 Hospital is required to have a UR plan
Added 2 EPs (Elements of Performance) 17 and 18
Must also have a UR committee which consists of at
least two members who are physicians
The committee is responsible for reviewing the
medical necessity of admissions, LOS, and services
for M&M patients
Revisions made to comply with the CMS CoPs
Also made a change to LD.04.01.05 that went into
effect January 12, 2011
8
TJC Standard Changes
LD.04.01.05 The hospital manages its programs
effectively
For psychiatric hospitals that use accreditation for
deemed status purposes:
The hospital has a director of social work services
who monitors and evaluates the social work
services furnished
Note: Social work services are furnished in
accordance with accepted standards of practice
and established P&P
9
Mandatory Compliance
Hospitals that participate in Medicare or Medicaid
must meet the COPs for all patients in the facilities
Not just those patients who are Medicare or
Medicaid
Hospitals accredited by TJC, AOA, or DNV
Healthcare have what is called deemed status
This means you can get reimbursed without going
through a state agency survey
Can still get complaint or validation survey
10
CMS Hospital CoPs
All Interpretative guidelines under state operations
manual are found at this website1
Appendix A, Tag A-0001 to A-1164 and 422
pages long
Manuals
Manuals are now being updated more frequently
Still need to check survey and certification
website once a month and transmittals 2
1 http://www.cms.hhs.gov/manuals/downloads/som107_Appendicestoc.pdf
2 http://www.cms.gov/Transmittals/01_overview.asp
11
Location of All of CMS CoPs Manuals
all manuals at
www.cms.hhs.gov/manuals/downloads/som107_Appendixtoc.pdf
12
Hospital CoP Manual Dec 22, 2011
http://cms.hhs.gov/manua
ls/Downloads/som107ap_
a_hospitals.pdf
13
CMS CoP
The Utilization Review section (abbreviated UR)
starts at tag 652
Has not been updated in long time
TJC amended the leadership chapter (LD.04.01.01) to
require a UR plan and UR committee with at least two
physician members
Added 2 EPs to comply with the MIPPA or Medicare
Improvements for Patient and Providers Act
The Discharge Planning session starts at tag 800
Watch for changes in the future in discharge planning in light of
the concern for preventing unnecessary readmissions
14
Utilization Review
Important in healthcare for many reasons
Making sure quality care is provided
In most cost effective manner
To reduce hospital admissions and length of stays
Want to make sure care is medically necessary especially
in light of the RACs or recovery audit contractors
Hospital should make sure has good UR plan and
UR staff
So what’s in your UR plan and in your UR program??
Should update it on an annual basis
15
Utilization Review Plan
16
Utilization Review Critical Access Hospitals
Currently Medicare reimbursement for CAHs is not
based on DRG designation so not subject to
mandatory reviews
No similar UR section in the CAH manual for Medicare
patients
However, Rural Healthcare Quality Network (RHQN)
recommends hospitals conduct internal reviews using the
InterQual criteria if possible (many private insurers use)
Recommend this even though other criteria sets are
available and less costly
Notes that in the future mandatory reviews may become
a reality
17
Utilization Review
Certification (justification) may be required for
certain procedures or a hospital stay before an
insurance company will pay for the stay
– LOS usually assigned by physician or nurse reviewer,
hospital committee, insurance provider or a combination
of the four
Medicare reviewers currently use InterQual criteria
when reviewing medical records to establish if
inpatient admissions were medically necessary
InterQual (or Milliman-USA) criteria are used by case
managers when conducting inpatient utilization review
18
Utilization Review
InterQual criteria are clinically based on best practice,
clinical data and medical literature
The criteria are updated continually and released
annually
The criteria is the first level screening tool to assist in
determining if the proposed services are clinically
indicated and in the appropriate setting
Can’t be use to deny a case as only physicians determine
clinical appropriateness
If does not meet then case is referred to a physician
reviewer for further determination of medical necessity
19
Utilization Review
Hospital and the attending physician will have the
opportunity to provide additional information on the
inpatient Medicare patient that may not have been
available to the physician reviewer
Of course, case may still be denied and there will be
opportunity to request a review by a different
physician reviewer
If second physician reviewer denies it then
opportunity to have case reviewed by an
administrative law judge (ALJ)
If denied, Medicare takes money back for payment of
the hospital stay
20
QIO Role in UR
This is why it is important for hospitals to respond back
to notices in a timely manner
This is the amount of time indicated on the letters
received from the Quality Improvement Organizations or
QIOs
The QIO does the peer review activity for CMS
Every state has a QIO under contract by CMS
QIO is involved with the Scope of Work (SOW) which is
updated every 3 years
9th SOW started August 2008 thru July 31, 2012 and 14 states worked
on care transition project (See MedQic)
21
Medicare Quality Improvement Org Program
The Medicare QIO program was created by law in
1982 to improve quality and efficiency of services to
Medicare patients
First phase in the early nineties did this through
peer review (PRO) to identify cases where
professional standards were not met for initiating
corrective actions
In second phase, had significant changes with how
to improve care and promotion of public reporting
and development of scope of work projects
22
CMS and Quality of Care
IOM March 2006 report recommended changes and
CMS makes improvements as result of the MMA
Law
Medicare Prescription Drug, Improvement, and
Modernation Act of 2003, section 109(d)(1)
CMS views QIO program as the cornerstone to
improve quality and efficiency for Medicare patients
CMS undertaking activities to manage and measure
quality and they want value based purchasing and
has a roadmap
More under discharge planning
23
9th Scope of Work SOW
Many times surveyor will ask to see if the hospital
has signed a contract with their QIO to participate in
the SOW
Many times if this is done CMS surveyor may not
scrutinize the UR standards
14 states worked on the Care Transition Project to promote
seamless transition across settings including hospital to home
and to prevent readmissions
Ten focus areas; heart failure, MRSA, pressure ulcers, R&S,
AHRQ culture tool, surgical care, drug safety, public reporting,
LD and quality assessment tool
Focused disparities (diabetes) and chronic kidney disease
24
9th Scope of Work SOW
QIOs will continue to review quality of care given to
Medicare patients, beneficiary appeals of certain
notices, potential EMTALA, and implementing QI
activities as a result of case reviews, sanctions etc
Some states adopted some of the initiatives
Some measures overlap with IHI (Institute for
Healthcare Improvement) 5 Million Lives Campaign
and 100K live campaign
Some also overlap with American Heart Association
on the Get with the Guidelines campaign (GWTG)
25
10th Scope of Work QIO
10th scope of work started August 1, 2011 and
continues for three years
Will continue efforts to prevent unnecessary
hospitals and goal is 20% reduction
Has community based care transition program
Also patient safety goals as to reduce hospital
acquired conditions by 40% (falls, CAUTIs, staff
turnover, etc.), reduce ADEs,
Improve quality through value-based purchasing
Reduce HAI (CAUTIs, CLABSIs, CDIs, SSI)
26
Medical Necessity
CMS takes the position that whether a patient
should be admitted as an inpatient is a complex
medical judgment that should be made by the
physician based on;
Severity of the “signs and symptoms” exhibited by
the patient,
Medical probability of an adverse outcome for the
patient, and
The need and availability of diagnostic studies
See MLN Matter SE1037
27
Transmittal SE1037 1/25/2011
28
Inpatient Review for Medicare Patients
A tool used by the QIO may be helpful to determine
medical necessity but does not guarantee payments
for admission or continued stay
Demographics
Patient name, ID number
Attending Name and contact information
The day or dates under review
SI (symptom intensity) How sick is the patient? This
places the patient’s services in context with their clinical
condition and is needed both for the initial review and
for concurrent review
29
Medical Necessity
Symptom intensity (continued)
What is the main clinical issue?
Abnormal vital signs?
Pain present- where, what is the cause?
Neurological status: alert to obtunded
Brief description of diagnostic tests (especially if lab
or x-rays are abnormal)
Any consultations and evaluations or procedures?
30
Intensity of Services
IS (Intensity of services) What care is the patient
receiving?
IV medications and frequency
Any IV PRN meds given for nausea, pain? How
often each day?
IV Fluids/ TPN
Blood or blood products (should have a HCT as a
reason)
Oxygen needed? FiO2 and route? ABGs done or
O2 sats?
31
Discharge Screens
DS (Discharge Screens) What is the long-term
plan? An “unsafe” discharge will initiate a quality of
care review.
What is the expected destination after
hospitalization?
What discharge planning activities are being done
What care needs are there post discharge?
Educational Needs?
Are there any significant psychosocial issues?
32
Intensity of Services
Intensity of Services continued
Diet/Tube feeds/gavage (what is infants weight)
If patient is on a sliding scale, What were the
high/low glucose values? How many coverage
units were given on each day (not the routine
doses)?
Wound management: describe wound and
dressing/debridement/special issues
Any other treatments or therapies?
33
MedQIC
MedQIC has the quality net website with free
resources for QI interventions, tools, and toolkits
http://www.qualitynet.org/dcs/ContentServer?pagen
ame=Medqic/MQPage/Homepage
Sign up to get their free monthly publication called
MedQiC (Medicare Quality Improvement
Community)
Purpose is to share resources including resources
on the 9th scope of work, delirium, depression,
infections, incontinence, restraint, UTI, patient
safety, transitions in care, AV fistula first, etc.
34
35
CMS Guidance on Hospital Inpatient Admissions
Medical necessity is a hot button with the RACs,
Medicare Administrative Contractors (MACs), fiscal
intermediaries (FIs) and comprehensive error rate
testing (CERT) contractors
CMS released an educational guideline to assist
hospitals regarding inpatient admission decisions
To help ensure that hospitals are using proper
screening criteria to analyze documentation and
make medical necessity determinations
Chapter 6 of the Medicare Program Integrity Manual, Section 6.5 is
available at http://www.cms.gov/manuals/downloads/pim83c06.pdf on
the CMS website
36
37
Utilization Review A-0652
Hospital must have a UR plan that provides for
review of services furnished by the institution and
the members of the MS to Medicare and Medicaid
beneficiaries
UR plan should state responsibility and authority of
those involved in the UR process
Surveyor will make sure activities performed as in
UR plan
Need to include review of medical necessity of
admissions
38
Utilization Review
Review of medical necessity for:
Appropriateness of the setting
Extended stays and
Professional services rendered
This is really important in light of the Recovery
Audit Contractors or RACs
American Hospital Association, AHIMA, and CMS has
website of resources for the RACs
RAC program to identify improper Medicare payments
including overpayment and underpayments
39
AHA Website on RAC Program
http://www.aha.org/aha/issue
s/RAC/index.html
40
CMS RAC Website
http://www.c
ms.gov/rac
41
http://ahima.org/resources/rac.aspx
42
Survey Procedure Tag 652
These are the questions to the surveyors to verify
Determine that the hospital has a utilization review plan
for those services furnished by the hospital and its
medical staff to M&M patients.
Verify through review of records and reports, and
interviews with the UR chairman and/or members that UR
activities are being performed as described in the hospital
UR plan.
Review the minutes of the UR committee to verify that
they include dates, members in attendance, extended stay
reviews with approval or disapproval noted in a status
report of any actions taken.
43
UR Plan
UR Plan should say who is on the UR committee
Such as the physician advisor, CNO, discharge planners,
social services, business office manager, HIM director,
administration, UR nurse, billing office, etc.
Should discuss meeting frequency such as meets
once a month
It should address conflicts of interest so anyone
with financial interest in the hospital can not be on
the committee
Should include a confidentiality section so all data,
minutes, worksheets are confidential
44
Functions of a UR Committee
Should include functions of the UR committee such
as:
To establish and carry out a program of admission
certification and continued stay review of all patients
in accordance with applicable state and federal laws
and regulations
To supervise the utilization review activities of non
physician reviewers
To assure coordination between concurrent review
activities, quality assurance, and risk management
activities, and reimbursement agencies
45
Functions of the UR Committee
To assist in the selection and ongoing modification of
criteria and standards
To recommend changes in hospital procedures, medical
Staff practices or continuing education programs as
indicated on analysis of review findings
To serve as utilization review committee for the skilled swing
bed activities
To act on any topics referred to them by the Medical Staff,
Administration, or any other hospital committee
To address potential over-utilization or under utilization
issues
46
UR Plan
UR plan can include the method of review
All patients admitted to the hospital will reviewed by the
UR nurse for appropriateness and medical necessity
Includes M&M patients, CHAMPUS, patient insurance
covered by private contract, self pay, etc
What guidelines are used such as InterQual or Milliman
etc.
Concurrent reviews are done using the same criteria or
the information provided by the insurers
If criteria does not exist then will work with physician and
patient and family to move the patient to the appropriate
level of service
47
UR Plan
If UR nurse sees unusually high costs or frequent
ordering of excessive services then can talk to
physician advisor
Or can subject case to Preadmission Review or indepth peer review
Decisions made by UR nurse will be based on
standards adopted by the MS and QIO
Include in the policy the preadmission review process
Precertification of elective surgeries should be done by
the physician’s office but hospital will verify precert
Include admission review process
48
Utilization Review
Make sure you get observation rules correct
especially with condition code 44
CMS issue UR CoP Memo June 2, 2007
Exception for UR plan is if the Hospital has an
agreement with the QIO in their state to assume
binding review
Hospitals may have a contract with QIO to review
admissions, quality, appropriateness and diagnostic
information related to Medicare inpatients
Surveyor will look to see if hospital has a signed
contract with their state QIO
49
Composition of UR Committee 654
Consists of 2 or more practitioners who carry
out UR function
At least 2 members must be doctors
The UR committee must be either a staff
committee of the hospital or
A group outside that has been established
by the local medical society for hospitals in
that locale and established in a manner
approved by CMS
50
UR Committee 654
A committee may not be conducted by an
individual who has a direct financial or
ownership interest (5% or more) or
Who was professionally involved in the care
of the patient whose case is being reviewed
Surveyor will look to see if the governing
board has delegated UR function to a outside
group if impracticable to have a staff
committee
51
Frequency of Review 655
UR plan must provide review for
Medicare/Medicaid (M/M) patients with
respect to medical necessity
Admissions (before, at, or after admission)
– Usually should screen within one working day of admission and
use severity of illness or intensity of service as discussed
previously
Duration of stay
Professional services furnished including drugs
and biologicals
52
Scope of Reviews A-0655
Reviews may be on a sample basis except for
reviews of cases assumed to outlier cases
because of extended stay cases or high costs
Surveyor will examine UR plan to determine if
medical necessity is reviewed
P&P should state what to do such as UR nurse speaks
with attending, goes to the physician reviewer, when
ABNs are issued, IM Notices, QIO guidelines etc.
If IPPS hospital there should be a review of the
duration of stay in cases assumed to be outlier
53
Admissions or Continued Stay
Determination that admission or continued stay
is not medically necessary is made by one
member of UR committee if the physician
concurs with determination or fails to present
their views when afforded the opportunity
Must be made by two members in all other cases (656)
Before determination not medically
necessary, UR committee must consult the
MD responsible for the care and afford
opportunity to present their views
54
Hospital Discharge Summary Form
55
Admissions or Continued Stay
Then committee must provide written notification no
later than two days after determination to the hospital,
patient and practitioner responsible for care
If attending doctor does not respond or contest the
findings of the committee, the findings are final
If physician of UR committee finds not medically
necessary no referral of committee is necessary and he
may notify the attending doctor
If non-physician makes the determination it must go to
the committee or the physician reviewer
A non-physician can not make this final determination
56
Review of Professional Services 658
The committee must review professional services
provided
To determine medical necessity
And to promote the most efficient use of available
health facilities and services
Topics for the committee may include overuse or
underuse of necessary services
Timeliness of scheduling of services such as
diagnostic and operating rooms
57
Discharge Planning
Discharge planning is important in today’s
environment especially in light of reform laws
If hospital do not do this right and the result is a
higher that average readmission rate in 2012, the
hospital could be financially penalized by CMS
20% of Medicare patients are readmitted within 30
days
CMS is expected to make some changes to this
section because of this
Hospitals need to reengineer the discharge process
58
Patient Protection and Affordable Care Act
The new law establishes a VBP program, or
value-bases purchasing, to pay hospitals for
their actual performance
Measures selected for pay include those used
in the Medicare pay for reporting program such
as measures for heart attack, heart failure,
pneumonia, surgical care and patient
satisfaction (HCAHPS)
Purpose to improve coordination, quality and
efficiency of health care services
59
Patient Protection and Affordable Care Act
Must develop episode-of-care and post-acute care
quality measures
Hospitals are required to submit data on these quality
measures through an EHR which will be posted on
hospital compare
Law specifies the following episode-of-care quality
measures
Functional status improvement
Rates of avoidable hospital readmissions
Rates of discharge to the community
Rates of admission to an emergency department after a
hospitalization
60
Readmission Rates Vary
Readmission rates vary widely in the US
Too often quality of care during transition from hospital to
home is not good
Data shows readmission rate for MI and CHF vary
Found only modest association between performance on
discharge measures and patient readmission rates
Public reporting unlikely to yield large reductions in
unnecessary readmissions
We need to improve in the ambulatory section
See A. K. Jha, E. J. Orav, and A. M. Epstein, Preventing
Readmissions with Improved Hospital Discharge Planning,
NEJM Dec 31, 2009 361 (27):2637-2645
61
Readmissions and Discharges
One in 5 hospital discharges (20%) is complicated
by adverse event within 30 days
20% were readmitted within 30 days with 1/3 leading to
disability
Often leads to visits to the ED and rehospitalization
6% of these patients had preventable adverse
events
66% were adverse drug events
The incidence and severity of adverse events affecting patients
after discharge from the hospital. Forster AJ, Murff HJ,
Peterson JF, Gandhi TK, Bates DW. Ann Intern Med.
2003;138:161-167
62
Preventing Readmissions
HHS study finds a high rate of Medicare patient
deaths due to adverse events (AE)
15,000 Medicare patients experience an AE during
healthcare delivery that lead to their death every
month
Nov 16, 2010 OIG study
Found 1 in every 7 discharges (13.5%) experience
an AE and the cost to CMS is $324 million
44% of all AE were preventable and 51% were not
November 2010, OEI-06-09-00090
63
64
AHA Guide to Reduce Avoidable Readmissions
AHA had committees look at the issue of how to
reduce unnecessary hospital readmissions
AHA published several memos and a 2010 Health
Care Leader Guide to Reduce Avoidable
Readmissions
Issues memo on Sept 2009 on Reducing
Avoidable Hospital Readmissions
Includes evaluation of post acute transition
process which is the process of moving from the
hospital to home or other settings
65
AHA Guide to Reduce Readmissions
66
CMS Discharge Checklist
CMS website recommends the discharge planning
team use a checklist to make transfer more efficient
It is available at www.medicare.gov
Previously research showed the value of hospital
discharge planners using a discharge checklist
We need to dictate the discharge summary
immediately when the patient is discharged
We need to document that it is in the hands of the
family physician
67
CMS Your Discharge Planning Checklist
68
69
CMS
Discharge planners should be a member of the
hospital committee to prevent unnecessary
readmissions
Discharge planners and transition coaches may
actually make the physician appointments
Ensure medication information is clearly understood
by the patients and use pharmacists when needed
in the process
CMS discharging planning standards start at tag
number 800
70
Things to Consider
Form a committee on redesigning the discharge process
Do a literature search and pull articles
Look at the different transition studies that have been
done and which ones have been successful
Care Transition, Transition of Care, RED, Guided care, H2H, IHI
Transforming Care at the Bedside, STAAR, Boost, GRACE,
Interact, Evercare, etc.
Have physician dictate discharge summary as soon as
patient is discharge
Hospitals needs to get it into the hands of the primary
care physician and document this in the chart
71
Things to Consider
Medical staff should dictate what needs to be in the
discharge summary beyond what CMS and TJC
require
Hospital should schedule all follow up appointments
with practitioners for the patients
Hospital should put in writing for the patient and in
the discharge summary
Any tests that are pending that are not back yet
Any future tests and these should be scheduled before the
patient leaves the hospital
72
Things to Consider
Use a discharge checklist for staff to use
Pa Patient Safety Authority has one called “Care at
Discharge” at
http://patientsafetyauthority.org/EducationalTools/PatientSafetyTools/Pages/home.aspx
Society of Hospital Medicine has one at
www.hospitalmedicine.org/AM/Template.cfm?Section=Quality_Improvement_Tools&Template=/CM/
ContentDisplay.cfm&ContentID=8363
Give patients a copy of the CMS checklist “Your
Discharge Planning Checklist” at
www.medicare.gov/Publications/Pubs/pdf/11376.pdf
Give a list of medications with times and reason for
taking
73
Things to Consider
Ensure education on all new meds and use teach
back to ensure education and give information in
writing
Ensure patient is given a copy of the plan of care
Give patient in writing their diagnosis and written
information about their diagnosis
Have patient repeat back in 30 seconds
understanding of their discharge instructions
Includes symptoms that if they occur what you want
to do and who to call
74
Things to Consider
Call back all patients discharged and review
information and reinforce discharge instructions
Have a call back number that patients and families
can use 24 hours a day, seven days a week
Reconciling the discharge plan with national
guidelines and critical pathways when relevant
Assess your hospital’s readmission rate
Pull charts and review for any patient who is
readmitted within 30 days
75
Medication List
76
Appointments for Follow Up
77
Discharge Planning A-800
Must have a discharge planning process that
applies to all patients
Inpatients and outpatients
P&P must be in writing
Written discharge planning process must reveal a
clear process to be followed
Necessary to prevent readmission
Surveyor will review patient care plans for discharge
planning interventions
78
So What’s in Your P&P?
79
Discharge Protocol for Babies
80
Identification of Patients 800
Must identify at early stage of hospitalization,
all patients who are likely to suffer adverse
consequences if no discharge planning
No national tool to do this
May include factors as functional status, cognitive
ability and family support
Patients at high risk should be identified from
screening process
Time to do left up to the hospital but as early as
possible
81
Case Management Consults
82
Discharge Planning Evaluation 806
Hospital must provide a discharge planning
evaluation to patients or upon the request of
the physician
Needs assessment can be formal or informal
Assess factors on what the patient will need
when discharged; bio-psychosocial needs and
patient and caregiver’s understanding of
discharge needs
Can be a tool or protocol
83
Discharge Planning Evaluation
Surveyor will ask how patients are made aware of
their right to request a discharge plan
Many hospitals include this in the patient’s rights
which are given to the patient in writing
Can also be posted in signs
Must be given the pamphlet “Important message
from Medicare” if Medicare patient
Patients given within 2 days of admission and must sign and
date
Patients are given again within 2 days of discharge if admitted
more than two days
84
Discharge Planning Responsibility 807
RN, SW, or qualified person must develop and
supervise the development of the evaluation
Person who does discharge planning evaluation
needs to have experience and knowledge of social
and physical factors that affect functional status to
meet patient needs
Such as in emphysema if needed to coordinate
respiratory therapy, nursing care, financials for home
health
Must have knowledge of community resources
Ideally, discharge planning is interdisciplinary process
85
Evaluation 808
Discharge planning evaluation must include
likelihood of needing post-hospital services
and availability of services
Keep complete file on community based
services such as LTC, sub acute care, and
home care
Is physical, speech, OT or RT needed?
Use the QAPI program to determine if
discharge planning process is effective
86
Self Care Evaluation 809
Discharge planning evaluation must include if
patient can do self care and return to pre-hospital
environment
Assess willingness of patient and family to do care
Inform patient of freedom to choose providers or
post hospital care (823)
Give list of Medicare certified HHA that serve your area
(SSA 1861) including ownership information
Must assess if need hospice or LTC and give list of
Medicare certified ones in your area
Document in the medical record that the list was given
87
Discharge Planning 809
Hospital can develop its own list or can for SNF can
also print out list from nursing home compare
website
Surveyor to review a sample of discharge planning
evaluations
Will note if interdisciplinary input is documented
Counsel patient and family for post hospital care
(822)
88
Timely Discharge Evaluation 810
Hospital must complete the evaluation timely
to avoid unnecessary delays in discharge
So appropriate arrangements can be made
Assessment should start soon after
admission
Surveyor will review several patient discharge
plans for appropriate coordination of health
and social resources
89
Discharge Evaluation 811
The hospital must include the discharge
planning evaluation in the patient’s medical
record
This is necessary to establish an appropriate
discharge plan
Must discuss the results of the evaluation
with the patient
Transitions in care project show increased
utilization of home health and LTC services
90
Patient Discharge Plan
91
Discharge Plan
The hospital must make sure that the discharge
plan requirements are met (817)
RN, social worker, or other qualified person must
develop or supervise the development of the
discharge plan if one is needed (818)
Make sure staff are trained and licensed
Patients have the right to participate in the
development and implementation of their plan of
care
Physicians can request a discharge plan (819)
92
Discharge Plan
Hospital must arrange for the initial implementation
of the patient’s discharge plan (820)
This includes arranging for the post hospital services and
care
This includes educating the patient about their post
hospital care plans
Hospital must reassess the patient discharge plan if
there are factors that affect the continuing need of
the plan
Reassessment takes place and the plan is updated as
needed
93
Discharge Plan
Patients and family members or other interested
parties are counseled to prepare them for post
hospital care (822)
Patients need to be kept of the progress
May need to demonstrate or verbalize the care
need
Teach back is good method to verify knowledge
or return demonstrations of procedures such as
emptying a foley or packing a wound
94
Discharge Plan
If in MCO hospital must indicated which ones have
contract with home health or LTC (826)
Hospital must now document in the medical record
that the list of home health or LTC facilities was
presented to the patient (827)
Rewrite your P&P to include this
Hospital must inform patient of freedom to choose
post hospital provider (828) and respect their
wishes (829)
Disclose any financial interests
HHA may request to be on the list
95
Transfer or Referral 837
Must transfer or refer patients to appropriate
facilities, agencies, or outpatient services for follow
up care
Must send along necessary medical records
Make sure patients get appropriate post hospital
care
Remember the federal EMTALA law for ED patients
Must document if patient refuses discharge
planning services
Written authorization before release of information
96
CMS Hospital Worksheets Third Revision
October 14, 2011 CMS issues a 137 page memo in the
survey and certification section
Memo discusses surveyor worksheets for hospitals by
CMS during a hospital survey
Addresses discharge planning, infection control, and
QAPI
It was pilot tested in hospitals in 11 states and on May
18, 2012 CMS published a second revised edition
Piloted test each of the 3 in every state over summer 2012
November 9, 2012 CMS issued the third revised
worksheet which is now 88 pages
97
CMS Hospital Worksheets
Will select hospitals in each state and will complete
all 3 worksheets at each hospital
This is the third and most likely final pilot and in
2013 will use whenever a validation survey is done
at a hospital by CMS
Third pilot is non-punitive and will not require action
plans unless immediate jeopardy is found
Hospitals should be familiar with the three
worksheets
98
Third Revised Worksheets
www.cms.gov/SurveyCertificationGe
nInfo/PMSR/list.asp#TopOfPage
99
CMS Hospital Worksheets
Goal is to reduce hospital acquired conditions
(HACs) including healthcare associated infections
Goal to prevent unnecessary readmission and
currently 1 out of every 5 Medicare patients is
readmitted within 30 days
Many hospitals (66%) financially penalized after
October 1, 2012 because they had a higher than
average rate of readmissions
The underlying CoPs on which the worksheet is
based did not change
100
CMS Hospital Worksheets
However, some of the questions asked might not be
apparent from a reading of the CoPs
A worksheet is a good communication device
It will help clearly communicate to hospitals what is
going to be asked in these 3 important areas
Hospitals might want to consider putting together a
team to review the 3 worksheets and complete the
form in advance as a self assessment
Hospitals should consider attaching the
documentation and P&P to the worksheet
101
CMS Hospital Worksheets
The regulations are the basis for any deficiencies
that may be cited and not the worksheet per se
The worksheets are designed to assist the
surveyors and the hospital staff to identify when
they are in compliance
Will not affect critical access hospitals (CAHs) but
CAH would want to look over the one on PI and
especially infection control
Questions or concerns should be addressed to
[email protected]
102
Discharge Planning
There are 23 pages in the discharge planning
section and starts at page 66
Includes hospital information such as name,
address, CCN number as previously discussed
Will cite deficiencies on a CMS Form 2567 if
observed which is a statement of deficiencies
and plan of correction when used for validation
surveys
CMS discharge planning regulations and
interpretive guidelines start at tag 800
103
Discharge Planning Worksheet 3rd Revision
104
105
Discharge Planning Worksheet
Are discharge P&P in effect for all inpatients?
Is there evidence on every unit that there is
discharge planning activities?
Are staff following the discharge planning P&P?
Is there a discharge planning process for certain
categories of outpatients such as observation, ED
patients and same day surgery patients?
Could add questions to the assessment tool and
include in questions asked in pre-admission tests
for OP surgery
106
Discharge Planning Worksheet
For patients not initially identified as in need of
discharge plan, is there a process for updating this
based on changes in a patient’s condition?
Many hospitals have the nurse doing the admission
assessment ask a set of predetermined questions to see if
assistance is needed
How do you update this when there is a change?
Is a discharge plan prepared for each inpatient?
Does hospital have a process for notifying patients
they can request a discharge planning evaluation?
Or process for the patient representative to request
107
Discharge Planning Worksheet
Surveyor will interview patient to see if they were
aware they could request a discharge planning
evaluation
Can the hospital show that they gave the patient a
notice of their rights?
Will interview doctors and make sure they know
they can request a discharge planning evaluation
(819 and 806)
If doctor not aware will ask hospital to provide
evidence on how it informs the MS about this
108
Discharge Planning Worksheet
Will ask staff to describe the process for
physicians to order a discharge plan
Does P&P provide a process for ongoing
reassessment of discharge plan in case of
changes to the patient’s condition (819)?
Does hospital review discharge planning
process on an ongoing manner as through
PI?
109
Discharge Planning Worksheet
Does hospital track readmission rates as part of
discharge planning?
Does assessment include if readmission was
potentially preventable?
If preventable then did the hospital make changes
to the planning process?
Does hospital collect feedback from post-acute
providers for effectiveness of the hospital’s
discharge planning process?
This would include places like LTC, assisted living or
home health agencies
110
Discharge Planning Tracers
Has a discharge planning tracer section 4
Surveyors is to interview one or two inpatients
Surveyor is to review the closed medical record of
two or three patients who was discharged
Will try and include one patient who was readmitted
within 30 days
Will mark worksheet to show if it was an interview,
discharge planning document review, medical
record review or other document that was reviewed
111
112
Discharge Planning Tracers
Was the screening done to identify if the inpatient
needed a discharge planning evaluation?
Includes at the time of admission, after an admission but
at least 48 hours prior to discharge, or N/A
In some hospitals all patients get a discharge plan
Can staff demonstrate that the hospital’s criteria
and screening process for discharge evaluation
were correctly applied (800)?
Was discharge planning evaluation done by
qualified person (SW, RN) as defined in the P&P?
(806)
113
Discharge Planning Tracers
Are the results of the discharge planning evaluation
documented in the chart?
Did the evaluation include an assessment of the
patients post-discharge care needs?
Patient need home health referral
Patient needs bedside commode
Patient needs home oxygen
Patient needs post hospital physical therapy
Meals on wheels, etc.
114
Discharge Planning Tracers
Did the evaluation include an assessment of:
Patient’s ability to perform ADL (feeding, personal
hygiene, ambulation, etc.)?
Family support and ability to do self care?
Whether patient will need specialized medical
equipment or modifications to their home?
Is support person or family able to meet the patient’s
needs and assessment of community resources ?
Was patient given a list of HHA or LTC facilities in the
community and must be documented in the record
and the list appropriate (806)
115
Discharge Planning Tracers To LTC
Separate set of questions if patient admitted from
LTC or assisted living
Did evaluation include if LTC has capacity for patient to go
back there?
Does it include assessment if insurance coverage will
cover it if they go back there?
Was the discharge planning evaluation timely to allow for
arrangements if the patient needs to go back there
Was the patient’s representative involved in these
discussions?
Discharge plan needs to match the patient’s needs (811,
130)
116
Discharge Planning Tracers
Will look for evidence of hospital of patients and
support persons
Was patient referred back for follow up with their
PCP or a health center?
Was there a referral to PT, mental health, hospice,
OT etc. as needed?
Was there a referral for community based resources
such as transportation services, Department of Aging,
elder services etc.?
Arranged for needed equipment such as oxygen,
commode, wheel chair etc.
117
Discharge Planning Worksheet
If transferred to another inpatient facility was the
discharge summary ready and sent with patient?
The following controversial section was changed in
the 3rd revision
Was discharge summary sent before first postdischarge appointment or within 7 days of discharge?
Was follow up appointment scheduled?
Now says send necessary medical record
information to providers the patient was referred
prior to the first post-discharge appointment or 7
days, whichever comes first
118
Discharge Planning Worksheet
Was the necessary medical record information
ready at the time of transfer if patient sent to
another facility
Was there any part of the discharge plan that the
hospital failed to implement that resulted in a delay
in discharge
Was there documentation in the medical record of
results of tests pending at the time of discharge
both to the patient and the post hospital provider?
Was patient readmitted within 30 days?
119
Preventing Readmissions
It is the preventable ones that hospitals need to
work on
Medicare data shows that over half of patients
readmitted received no follow up care
Recent studies show interventions targeted at postacute care transition can reduce readmissions by
one third (Coleman and Naylor)
Technologies for Improving Post-acute Care Transitions,
Center for technology and Aging, Sept 2010
120
The End! Questions????
Sue Dill Calloway RN, Esq
AD, BA, BSN, MSN, JD CPHRM
President of Patient Safety and
Health Care Consulting
Chief Learning Officer of the
Emergency Medicine Foundation
www.empsf.org
Dublin, Ohio 43017
614 791-1468
[email protected]
Additional slides on TJC standards
121
Joint Commission Standard for Hospitals
PC.01.02.01 and RC.2.01.01 EP2 Medical record
must contain information on plan of care and
revisions to the plan of care and discharge
diagnosis
TJC has PC.01.03.01 which provided information
on planning the patient’s care
PC.02.02.13 has end of life standards
This is provided for reference
Discharge planners and social workers should be
familiar with these standards in addition to the floor
nurse caring for the patient
122
Planning the Patient’s Care PC.01.03.01
The hospital plans the patient’s care
Need to individualize the patient’s treatment based on
their unique needs
Treatment must be appropriate to the results of the
assessment performed
May need to modify the plan of care based on the
assessments done
Could result in transfer to another facility or discharge
EP1 Patient’s care is based on what is identified by
the assessments and reassessments and the
results of the diagnostic tests
123
Planning the Patient’s Care PC.01.03.01
EP5 The written plan of care is based on the
patient’s goals and the time frames, settings, and
services required to meet those goals
EP22 Staff need to evaluate the patient’s progress
in light of the goals and the patient’s plan of care
EP23 Hospital revises the plan of care and goals
based on the patient’s need
Failure to do a plan of care soon after the patient is
admitted and maintained it in the medical record
after the patient is discharged is a top problematic
standard with CMS
124
Patient Education PC.02.03.01
The hospital provides patient education and training
based on each patient’s needs and abilities
Patients are often discharged home earlier than in the
past
Patients may have to do more self care such as changing
bandages, drains to home infusion therapy
This makes patient education even more important
Also important to prevent unnecessary readmission
especially related to medication use
Patient learning needs must be assessed
Patient education is important issue to TJC
125
Patient Education PC.02.03.01
EP10 Education and training to patient will include
the following based on the patient’s condition and
assessed needs
Explanation of the plan for care
Basic health practices and safety
Safe medication use
Nutritional interventions, diets, supplements
Pain issues such as pain management and methods
Information on oral health (much information later on this
including oral bacterium (periodontal disease) as cause of
cardiovascular disease, MI, VAP, stroke, CAD)
126
Patient Education PC.02.03.01
EP10 Education and training to the patient
(continued)
Safe use of medical equipment
Safe use of supplies
Rehab to help the patient reach maximum independence
EP25 Must evaluate the understanding of the
education and training provided
Teach back is one method to verify understanding
Ask me three program by the National Patient Safety
Foundation
127
http://www.npsf.org
/askme3/
128
Use a Patient Education Form
129
Use a Patient Education Form
130
http://www.docstoc.com/docs/downloaddoc.aspx/?d
oc_id=35987557&pt=16&ft=11
131
Patient Education Checklist
132
Patient Education PC.02.03.01
EP27 The hospital provides the patient education
on how to communicate concerns about patient
safety issues that occur before, during, and after
care is received
Instructions might be to contact their physician after
discharge
May be if certain condition reoccurs to call 911 or
go to the closest emergency department
Patients when discharge should be informed of
signs and symptoms of when to return (TJC
discharge tracer)
133
Care After Discharge or Transfer
PC.04.01.01 states that the hospital has a process
that addresses the patient’s need for continuing care
after discharge or transfer
EP1 Hospital describes the reason for and conditions
under which the patient is discharged or transferred
For example care may no longer be medically necessary
Patient may need services that are not provided by your
hospital such as open heart surgery
EP2 Need to describe the process for shifting
responsibility to a new clinician or hospital or service
134
Care After Discharge or Transfer
EP3 Hospital describes mechanism for external
transfer of patient
Example would be to contact receiving hospital and get
acceptance, fill out transfer form, send medical records,
send in ambulance when appropriate etc.
Remember the federal EMTALA law for patients who in
the ED and are unstable
EP4 The hospital agrees with the receiving
organization about each of their roles to keep the
patient safe during transfer
May need transported by helicopter or ACLS or BLS unit
135
Care After Discharge or Transfer
EP22 Patients are informed of their rights to choose
among participating Medicare providers and the
hospital does not limit those qualified providers (DS)
EP23 and 24 During discharge planning if
determine patient needs home health or LTC then
give them a list of the ones available and document
you gave the list (DS)
This is a CMS requirement
The hospital can not just automatically send the patient to
their home health agency
It is truly the patient’s freedom of choice
136
Care After Discharge or Transfer
EP26 The hospital has written discharge planning
P&P applicable to all patients (DS)
Must also disclose any financial interest such as the
hospital owns the nursing home or the home health
agency
Remember to take care to prevent any unnecessary
readmissions to the hospital
Dictate the discharge summary immediately and
document that you got it into the hands of the PCP
who is going to see the patient post discharge
137
Assessment & Discharge PC.04.01.03
The hospital discharges or transfers the patients
based their assessed needs and the hospital’s
ability to meet those needs
EP1 Need to begin the discharge process early in
the patient’s admission
EP2 Identify any need for psychosocial or physical
care after discharge
EP3 Patient, family, staff, physician, LIPs etc all
participate in the planning the patient’s discharge or
transfer
138
Assessment & Discharge PC.04.01.03
EP4 Arrange the services the patient will need after
discharge before they leave
EP10 The hospital conducts reassessments of its
discharge planning process within its established
time frames for reassessment (DS)
EP11 The reassessment of the discharge planning
process includes a review of discharge plans to
determine if the discharge plans meet the needs of
patients (DS)
139
Education Before Discharge PC.04.01.05
Before the hospital discharges or transfers a patient
is informed and educated the patient follow-up care
EP1 When the patient needs to be discharged or
transferred this information is shared with the
patient along with the patient’s needs
EP2 Hospital informs the patient the kinds of care
that will be needed after discharge
Some patients will need to be in a LTC or might need
home health services or assisted living
140
Education Before Discharge PC.04.01.05
EP3 Hospital needs to give the patient information
about why they are being discharged or transferred
EP5 Patient must also be provided about any
alternatives to the transfer
EP7 The hospital needs to educate the patient
about continuing care the patient will need and how
to obtain this care
EP8 Patient must be given understandable
discharge instructions
Remember issue of low health literacy and studies show
patients may not understand discharge instructions
141
Communication Discharge to Service Providers
PC.04.02.01 state that when a patient is discharged
or transferred
The hospital gives information about the care
provided to the patient
And to other service providers who will provide the
patient with care
Continuity of care is important so that the next treating
practitioner has the information need to take care of the
patient
Communication is important for patient safety reasons and
to prevent readmissions
142
Communicate Information to Next Provider
PC.04.02.01 states that the hospital must inform
other service providers who will provide care to the
patient
When they are discharged or transferred about the
following (EP1);
Reason for discharge or transfer
Patient’s physical and psychosocial status
A summary of care provided
Patient’s progress toward goals
List of community resources given to the patient
143
Utilization Review Plans
2 new EPs effective January 1, 2011
LD.04.01.01 EP 17 and 18 (deemed status)
LD.04.01.01 EP 17: The hospital (and CAH distinct
units) has a utilization review plan that provides for
review of services furnished by the hospital and the
medical staff to patients entitled to benefits under
the Medicare and Medicaid programs. LD.04.01.01
EP 18: Utilization review activities are implemented
by the hospital/critical access hospital in
accordance with the plan
Discharge Planning Revised
There are 22 pages in the discharge planning section
and starts at page 66
Includes hospital information such as name, address,
CCN number as previously discussed
Will cite deficiencies on a CMS Form 2567 if observed
which is a statement of deficiencies and plan of
correction
CMS discharge planning regulations and interpretive
guidelines start at tag 800
Remember hospitals with a higher than average
readmission rate after Oct 2012 can be financially
penalized
145
Discharge Planning Worksheet
146
147
Discharge Planning Worksheet
Are discharge P&P in effect for all inpatients?
Is there evidence on every unit that there is
discharge planning activities?
Are staff following the discharge planning P&P?
Is there a discharge planning process for certain
categories of outpatients such as observation, ED
patients and same day surgery patients?
Could add questions to the assessment tool and
include in questions asked in pre-admission tests
for OP surgery
148
Discharge Planning Worksheet
For patients not initially identified as in need of
discharge plan, is there a process for updating this
based on changes in a patient’s condition?
Many hospitals have the nurse doing the admission
assessment ask a set of predetermined questions to see if
assistance is needed
How do you update this when there is a change?
Is a discharge plan prepared for each inpatient?
Does hospital have a process for notifying patients
they can request a discharge planning evaluation?
Or process for the patient representative to request
149
Discharge Planning Worksheet
Surveyor will interview patient to see if they were
aware they could request a discharge planning
evaluation
Can the hospital show that they gave the patient a
notice of their rights?
Will interview doctors and make sure they know
they can request a discharge planning evaluation
(819 and 806)
If doctor not aware will ask hospital to provide
evidence on how it informs the MS about this
150
Discharge Planning Worksheet
Will ask staff to describe the process for
physicians to order a discharge plan
Does P&P provide a process for ongoing
reassessment of discharge plan in case of
changes to the patient’s condition (819)?
Does hospital review discharge planning
process on an ongoing manner
Removed section that said at least quarterly
How often does your hospital do this?
151
Discharge Planning Worksheet
Does hospital track readmission rates as part of
discharge planning?
Does assessment include if readmission was
potentially preventable?
If preventable then did the hospital make changes
to the planning process?
Does hospital collect feedback from post-acute
providers for effectiveness of the hospital’s
discharge planning process?
This would include places like LTC, assisted living or
home health agencies
152
Discharge Planning Tracers
Has a discharge planning tracer section 4
Surveyors is to interview one or two inpatients
Surveyor is to review the closed medical record of
two or three patients who was discharged
Will try and include one patient who was readmitted
within 30 days
Will mark worksheet to show if it was an interview,
discharge planning document review, medical
record review or other document that was reviewed
153
154
Discharge Planning Tracers
Was the screening done to identify if the inpatient
needed a discharge planning evaluation?
Includes at the time of admission, after an admission but
at least 48 hours prior to discharge, or N?A
In some hospitals all patients get a discharge plan
Can staff demonstrate that the hospital’s criteria
and screening process for discharge evaluation
were correctly applied (800)?
Was discharge planning evaluation done by
qualified person (SW, RN) as defined in the P&P?
155
Discharge Planning Tracers
Are the results of the discharge planning evaluation
documented in the chart?
Did the evaluation include an assessment of the
patients post-discharge care needs?
Patient need home health referral
Patient needs bedside commode
Patient needs home oxygen
Patient needs post hospital physical therapy
Meals on wheels, etc.
156
Discharge Planning Tracers
Did the evaluation include an assessment of:
Patient’s ability to perform ADL (feeding, personal
hygiene, ambulation, etc.)?
Family support and ability to do self care?
Whether patient will need specialized medical
equipment or modifications to their home?
Is support person or family able to meet the patient’s
needs and assessment of community resources ?
Was patient given a list of HHA or LTC facilities in the
community and must be documented in the record
and the list appropriate
157
Discharge Planning Tracers To LTC
Separate set of questions if patient admitted from
LTC or assisted living
Did evaluation include if LTC has capacity for patient to go
back there?
Does it include assessment if insurance coverage will
cover it if they go back there?
Was the discharge planning evaluation timely to allow for
arrangements if the patient needs to go back there
Was the patient’s representative involved in these
discussions?
Discharge plan needs to match the patient’s needs (811,
130)
158
Discharge Planning Tracers
If patient discharged home is their initial
implementation of the discharge plan?
Did staff provide training to patient including
recognized methods such as teach back?
Were the written discharge instructions legible and
use non-technical language (low health literacy)
Was a list of all medication patient will take after
discharge given with a clear indication of any
changes?
TJC revised their 5 EPs on medication reconciliation July
1, 2011
159
Medication List
160
Discharge Planning Tracers
Will look for evidence of hospital of patients and
support persons
Was patient referred back for follow up with their
PCP or a health center?
Was there a referral to PT, mental health, hospice,
OT etc. as needed?
Was there a referral for community based resources
such as transportation services, Department of Aging,
elder services etc.?
Arranged for needed equipment such as oxygen,
commode, wheel chair etc.
161
Discharge Planning Worksheet
If transferred to another inpatient facility was the
discharge summary ready and sent with patient?
Was discharge summary sent before first postdischarge appointment or within 7 days of
discharge?
Was follow up appointment scheduled?
Was there documentation in the medical record of
results of tests pending at the time of discharge
both to the patient and the post hospital provider?
Was patient readmitted within 30 days?
162
Appointments for Follow Up
163
Outstanding Labs or Tests
164
Patient Discharge Plan
165
Discharge Planning Tracers
Will look to make sure these were done and
did not delay discharge
Scheduling follow-up appointments
Filling prescriptions
Pharmacist meeting with patient and/or
family/support persons to review medication
regimen
Pharmacist reviewing discharge medication
orders prior to hospital departure
166
Discharge Planning Tracers
Will look to make sure these were done and
did not delay discharge (continued):
Home setting visitation by hospital staff
Transportation arranged for follow-up
appointments
Discharge planning checklists, e.g. CMS, AHRQ,
CAPS checklists
Note CMS has one for patients and PaPSA and
hospitalists have a checklist for physicians and
staff
167
CMS Your Discharge Planning Checklist
www.cfmc.org/caretransitions/patient_re
sources.htm
168
169
Two Discharge Check Lists
This lead to the development of a formal discharge
checklist to ensure communication at discharge
Transition of care for hospitalized elderly patients—
development of a discharge checklist for hospitalists.
Halasyamani L, Kripalani S, Coleman E, et al. J Hosp
Med. 2006;1:354-360
The Pa Patient Safety Authority has excellent resources
including suggested elements for a discharge checklist
See Care at discharge—a critical juncture for transition
to post hospital care. Pa Pat Saf Advis 2008
Jun;5(2):39-43
170
PaPSA Checklist
171
See Society of Hospital Medicine at
http://www.hospitalmedicine.org/AM/Template.cfm?
Section=Quality_Improvement_Tools&Template=/CM
/ContentDisplay.cfm&ContentID=8363
172
The End! Questions???
Sue Dill Calloway RN, Esq
AD, BA, BSN, MSN, JD CPHRM
President of Patient Safety and
Health Care Consulting
Chief Learning Officer of the
Emergency Medicine Foundation
www.empsf.org
Dublin, Ohio 43017
614 791-1468
[email protected]
173