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ANA view on posthospital regulations
ANA view on posthospital regulations
The American Nurses' Association (ANA) has filed objections to significant aspects of regulations proposed by the Social Security Administration of the US Department of Health, Education, and Welfare (HEW) that govern posthospital extended care and home health services. ANA said it objects to aspects of the regulations which appear to penalize short-term hospital patients and those who move directly from hospital to home. The regulations, published in the Federal Register in July 1975, also place the direction and accountability for nursing care with physicians, ANA said, and establish undue restrictions for home care services. The association expressed concern with provisions in the regulations which preclude involvement of nurses in critical decisions concerning patient access to health care services. The regulations do not recognize the responsibility of nurses to be accountable for nursing care, ANA said, and instead assign to physicians accountability for the plan of care for patients requiring extended care and home health services. Because such services are primarily skilled nursing services, ANA opposes assigning accountability for this care to physicians. The association said another major problem is that the regulations seek to establish national norms for extended care and home health services when norms have not been established for the preceding hospitalization. According to ANA, setting norms for presumed coverage for secondary levels of covered care when there are none for hos-
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pitalization is unreasonable. ANA cited statistics showing wide regional variations in the lengths of stay for hospitalized patients. At acute hospitals in northwestern regions of the country, the average length of stay is 15.2 days for patients over 65, but the average length of stay in the west is only 10.6 days. The intent of the law is to promote shorter hospital stays, the association said, but the norms established by the regulations would penalize patients who utilize the hospital for shorter times. Additionally, patients staying shorter periods in the hospital are more likely to need more extended or home health care than those who stay in the hospital longer. A third concern of the association is the restrictive impact the regulations would have on the field of home health. ANA said the regulations disregard the needs of patients who move directly from hospital to home and appear to promote patient movement from krospitalto skilled nursing facility. In addition, the number of visits and period of time allotted for home care are inadequate and do not allow for the individualization necessary in home care. Because of its concern, ANA requested an extension of the time allowed for comment on the proposed regulations. In a letter to ANA Executive Director Eileen M Jacobi, outgoing HEW Secretary Caspar Weinberger granted the extension to late August 1976. Weinberger indicated there was some urgency in issuing the regulations which must be done to implement section 228 of PL 92-603 that provides for advance approval for coverage of posthospital extended care and posthospital home health services under Medicare.
A O R N J n i r m n l . Decenther 1975, Vol 22. N o 6
The American Nurses' Association (ANA) has filed objections to significant aspects of regulations proposed by the Social Security Administration of the US Department of Health, Education, and Welfare (HEW) that govern posthospital extended care and home health services. ANA said it objects to aspects of the regulations which appear to penalize short-term hospital patients and those who move directly from hospital to home. The regulations, published in the Federal Register in July 1975, also place the direction and accountability for nursing care with physicians, ANA said, and establish undue restrictions for home care services. The association expressed concern with provisions in the regulations which preclude involvement of nurses in critical decisions concerning patient access to health care services. The regulations do not recognize the responsibility of nurses to be accountable for nursing care, ANA said, and instead assign to physicians accountability for the plan of care for patients requiring extended care and home health services. Because such services are primarily skilled nursing services, ANA opposes assigning accountability for this care to physicians. The association said another major problem is that the regulations seek to establish national norms for extended care and home health services when norms have not been established for the preceding hospitalization. According to ANA, setting norms for presumed coverage for secondary levels of covered care when there are none for hos-
946
pitalization is unreasonable. ANA cited statistics showing wide regional variations in the lengths of stay for hospitalized patients. At acute hospitals in northwestern regions of the country, the average length of stay is 15.2 days for patients over 65, but the average length of stay in the west is only 10.6 days. The intent of the law is to promote shorter hospital stays, the association said, but the norms established by the regulations would penalize patients who utilize the hospital for shorter times. Additionally, patients staying shorter periods in the hospital are more likely to need more extended or home health care than those who stay in the hospital longer. A third concern of the association is the restrictive impact the regulations would have on the field of home health. ANA said the regulations disregard the needs of patients who move directly from hospital to home and appear to promote patient movement from krospitalto skilled nursing facility. In addition, the number of visits and period of time allotted for home care are inadequate and do not allow for the individualization necessary in home care. Because of its concern, ANA requested an extension of the time allowed for comment on the proposed regulations. In a letter to ANA Executive Director Eileen M Jacobi, outgoing HEW Secretary Caspar Weinberger granted the extension to late August 1976. Weinberger indicated there was some urgency in issuing the regulations which must be done to implement section 228 of PL 92-603 that provides for advance approval for coverage of posthospital extended care and posthospital home health services under Medicare.
A O R N J n i r m n l . Decenther 1975, Vol 22. N o 6