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Involuntary Transfers & Discharges

Maintaining Compliance

Lost to Follow Up OR Involuntary Discharge?
Review this EQRS information sheet to ensure you are not violating regulations!

The number of displaced patients (patients with no facility willing to accept them) is a concern in Quality Insights Renal Network 5 and throughout the country. These patients are forced to go to hospital emergency rooms for treatment, thus contributing to an already over-burdened system, and also receiving little or no continuity of care. Network 5 supports the recommendations (pg. 90) on involuntary discharge from the Ethical, Legal, and Regulatory Subcommittee of the Decreasing Dialysis Patient-Provider Conflict Project.

Involuntary discharge is a last resort for managing difficult patient situations. The Conditions for Coverage (§ 494.180 (f)) recognize involuntary discharge for the following reasons:

  • The patient or payer no longer reimburses the facility for the ordered services;

  • The facility ceases to operate;

  • The transfer is necessary for the patient’s welfare because the facility can no longer meet the patient’s documented medical needs; or

  • The facility has reassessed the patient and determined that the patient’s behavior is disruptive and abusive to the extent that the delivery of care to the patient or the ability of the facility to operate effectively is seriously impaired…

Unfortunately, the incidence of involuntary discharge (IVD) seems to be increasing. We believe this trend is due partially to an increase in untreated mental illness in the ESRD population, stressors (both privately and professionally) experienced by staff, and also because of a general lack of knowledge about the IVD process and when it is appropriate. The Network is also seeing a lack of knowledge about appropriate documentation and intervention preceding an involuntary discharge. It is advised that facilities contact the Network for assistance in managing difficult patient behaviors before they escalate to the point where patients are no longer welcome in the facility.

Dialysis facilities are required to complete and submit an Involuntary Discharge Packet to the Network when discharging a patient involuntarily. 

The IVD Packet will help you:

  • Determine if the involuntary discharge is appropriate by reviewing the Conditions for Coverage

  • Follow the procedure required by CMS

  • Provide appropriate documentation as required by CMS

  • Correctly update the discharged patient in EQRS (formerly CROWNWeb)

  • Better serve the patient

Involuntary Discharge Packet

Position Statements