Involuntary Patient Discharge/Transfer (IVD/IVT) Policy and Procedures

Qsource ESRD Networks 10 and 12 actively work to understand and reduce the incident of involuntary patient discharges as part of our quality improvement efforts. All patients should have access to outpatient dialysis care, and all facilities should be working to prevent involuntary discharges.

We receive frequent calls regarding the process of involuntarily discharging a patient under the Conditions for Coverage (CfC). The interpretive guidelines (V Tags 766–767) specify involuntary discharge or transfer should be rare and preceded by demonstrated effort on the part of the interdisciplinary team to address the problem in a mutually beneficial way.  Efforts must be made to resolve the problems, and the interdisciplinary team must reassess the patient with an intent to identify any potential action or plan that could prevent the need for discharge or transfer of the patient involuntarily. The reassessment must focus on identifying the root causes of the disruptive or abusive behavior and result in a plan of care aimed at addressing those causes and resolving unacceptable behavior.

Reasons for Involuntary Discharge/Transfer

According to the ESRD Conditions for Coverage, there are only five sanctioned reasons for involuntary discharge/transfer (V766, V767) including: 

• 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.
• 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.
• In the case of immediate severe threats* to the health and safety of others, the facility may utilize an abbreviated involuntary discharge procedure.

Provider Resources

Qsource ESRD Networks have resources for healthcare providers to assist in clinical practice and to deal with difficult situations. If you are having difficulty with challenging patients, incorporate the Decreasing Dialysis Patient Provider Conflict (DPC) and addendum program. The DPC addresses proactive techniques to resolve such issues before progression to involuntary discharge. Conflict is never easy, and the unique settings of a dialysis center can make it even more challenging. Please download and provide an in-service for the staff.

Involuntary discharge should be the last resort. To ensure you are following the ESRD Conditions for Coverage correctly, please visit our website. Please download the resources and provide an in-service for the staff.

Utilizing Qsource ESRD Networks' resources and tools is a great way to assist with facility concerns and reduce the number of patient involuntary discharges. When you are faced with challenging patients and behaviors, notify the Network before situations escalate.  Early intervention provides time to review issues with the intent of preventing an involuntary discharge or transfer.

Please do not hesitate to call the Patient Services Department with any questions or concerns regarding this important matter.

Network 10

Keisha Wilson, MSW, LCSW

Patient Services Specialist

(317) 257-8265, press option 1

Network 12

Erica Anderson, MSW, LCSW

Patient Services Manager

(816) 880-9990, press option 2

This material was prepared by Qsource, an End-Stage Renal Disease (ESRD) Network under contract with the Centers for Medicare & Medicaid Services (CMS), an agency of the U.S. Department of Health and Human Services (HHS). Views expressed in this material do not necessarily reflect the official views or policy of CMS or HHS, and any reference to a specific product or entity herein does not constitute endorsement of that product or entity by CMS or HHS. 24.ESRD.03.051