Bundled Payments: Final Hip and Knee Rule

On November 16, CMS issued the final rule for bundled payment demonstration, lower extremity, effective April 1, 2016.  A single payment, made to a qualifying hospital in one of 67 regions/MSAs covers all aspects of the hospital care, the surgery, and any post-discharge, post-acute stay components through 90 days (from initial hospitalization). The payment exclusions … Read more

Modern Health Care Risk Management

The second most important function an executive and/or a governance board conducts (second only to planning) is risk management.  This key leadership function is evolving rapidly primarily due to the evolutionary movement around compliance (ACA, CMS, etc.) and the payer focal shift from episodic, procedural care to outcome or evidenced based care, pay-for-performance, etc.  Similarly, as government policy … Read more

Upcoming Webinar: CMS Proposed Reform Rule for SNFs

On August 20th, I will be conducting a webinar for HcPro on the CMS proposed rule to overhaul the existing federal Conditions of Participation for SNFs. Of a current 366 sections with the Code, CMS is proposing to change 212 sections.  This is the most sweeping overhaul of the federal code for SNFs since OBRA and PPS … Read more

CMS Releases Proposed New SNF Rule

Concurrent with the White House Conference on Aging, CMS released its “proposed” rules of reform for the SNF Conditions of Participation.  The proposed rule is set for publication tomorrow in the Federal Register but readers with interest can access the document/PDF on this site on the “Reports and Other Documents” page.  The Federal Conditions of Participation … Read more

Core Administrative Competency: SNF

As I have written before and readers know, I field as many questions and provide as many resources as I can “free” of charge.  My e-mail is publicly available for contact on this site and on my LinkedIn page.  The title of this post thus, is a reference to the many questions I’ve received as of … Read more

SNFs: A New Era in Post-Acute Care Begins

Over the years I have written about the changing landscape in post-acute care, principally due to the health policy ground swell resultant from the ACA (other reasons too but the ACA concretized them all, more or less). Boiled down, the fundamental driver of change is “pay for performance”; the notion that payment will migrate toward value … Read more

Medicare, Billing Audits and Self-Disclosure

Over the last six months or so, I’ve written a number of articles on the issue of SNFs, therapy contracts/contractors, and recent fraud settlements. I’ve also given a few presentations on the same subject, covering how fraud occurs, the relationships between therapy contractors, SNFs and Medicare, and the keys to avoiding fraud. A reader question based … Read more

SNFs, Therapy Contracts and Fraud: Redux

Yes another SNF, another therapy contract and more fraud settlements.  The only thing that isn’t different is the contractor – RehabCare once again (a coincidence?…not likely). In news released late last week, a Maine SNF settled with the Department of Justice for $1.2 million, allegations of improper Medicare billings for “unnecessary, inflated, and unreasonable” therapy … Read more

SNFs, Therapy Contracts and Fraud: Another Warning and Example

I know I sound redundant but clearly, the message is still not permeating through the industry (except for readers here). The Department of Justice and the OIG for the Department of Health are scrutinizing SNFs, their therapy billings, and the use of therapy contractors.  Why?  It is all due to a known and now routinely … Read more

Hospice: Risk/Reward for Institutional Growth

With the hospice market (in most areas) fairly well saturated and the core (source) demand from traditional referral sources “flat”, growing census is a challenge for agencies. Some agencies have experienced referral growth but alas, length of stay has shortened. Others have experienced erosion as, while improper, the “skilled to death phenomenon” erodes days and … Read more