CMS has released a new fact sheet to help skilled nursing facilities determine when an OBRA Discharge assessment is required. The resource provides a quick reference for MDS teams and reinforces existing guidance in the MDS 3.0 RAI User's Manual.
According to CMS, an OBRA Discharge assessment is only required when a resident meets one of the following criteria:
- Is discharged from the facility to a private residence.
- Is admitted to a hospital or other care setting (e.g., Assisted Living Facility).
- Has a hospital observation stay lasting more than 24 hours.
- Is transferred to a non-certified bed.
Key Clarifications
CMS highlights several situations that can create confusion for providers:
- An emergency department (ED) visit by itself does not automatically require an OBRA Discharge assessment, regardless of duration.
- If a resident is treated in the ED and returns to the facility without being admitted to the hospital or placed in observation status for more than 24 hours, an OBRA Discharge assessment is generally not required.
- An OBRA Discharge assessment is required when a resident remains in observation status for more than 24 hours, even if the resident later returns to the facility.
- A Leave of Absence (per the RAI Manual, Ch. 2, pg. 2-14) do not require an OBRA Discharge assessment.
The fact sheet is intended as a supplemental resource and does not replace the detailed guidance in the MDS 3.0 RAI User's Manual.
Bottom line: Facilities should review each transfer individually and follow MDS 3.0 RAI User's Manual guidance when determining whether an OBRA Discharge assessment is required.
Providers are encouraged to review the resource and share it with interdisciplinary team members involved in resident assessment and discharge processes. Questions may be sent to regulatory@ahca.org.