If a patient dies while under the care of the home health agency, do we have to complete a Discharge Summary?

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After two years under the “new” Conditions of Participation, I’ve had a question that has come up several times in the last few weeks, so thought I’d share:  If a patient dies while under the care of the home health agency, do we have to complete a Discharge Summary?

Researching the CoPs and Interpretive Guidelines:

Everything in the CoPs and Interpretive Guidelines states the reason for the discharge summary is to provide essential information to the patient’s next healthcare provider (typically the community physician or clinic staff) who will provide follow up care after the agency discharges the patient.

In the case of patient death, there is no need for follow up care, so there is no reason why a Discharge Summary would be required in this situation.  There is no specific statement in the CoPs that states a Discharge Summary would be required when a patient dies under home health agency care, but also there’s nothing that says a DC Summary would NOT be required – but remember, CMS never says what ISN’T needed.

I checked with a surveyor friend, and she agreed:

There is no guidance in the CoPs regarding sending a discharge summary in the case of a death.  We would not expect a discharge summary to be sent in this type of situation where the patient will not need any follow up care.

So, that’s one less thing we have to do!


Teresa Northcutt, BSN, RN, COS-C, HCS-D, HCS-H

Senior Associate Consultant | Selman-Holman, A Briggs Healthcare Company

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