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# Reg's Blog

Healthcare, Senior Living, Economics

## Sitemaps

- [XML Sitemap](https://rhislop3.com/sitemap.xml): Contains all public & indexable URLs for this website.

## Posts

- [Blog](https://rhislop3.com/blog/) - rhislop3
- [Managed Care Contracting Is a Margin Test](https://rhislop3.com/managed-care-contracting-margin-test/) - Managed care contracting now determines far more than a rate sheet. For post-acute and senior living leaders, it is a test of margin, access, and control.
- [The Impact of Value-Based Care](https://rhislop3.com/the-impact-of-value-based-care/) - How value based care affects operators: payment risk, data demands, referral strategy, and leadership decisions across post-acute and senior care.
- [Medicare Overpayment Demands and Risk](https://rhislop3.com/medicare-overpayment-demands-and-risk/) - Medicare overpayment demands can expose weak controls, strain cash flow, and invite scrutiny. Providers need a disciplined response before recoupment begins.
- [CMS Changes to SNF Quality Measure Thresholds](https://rhislop3.com/cms-changes-snf-quality-measure-thresholds/) - CMS changes SNF quality measure thresholds can reshape ratings, reimbursement risk, and survey exposure. Operators need to know what will move and why.
- [Friday Feature: Quality and the Revenue Connection (2019 version)](https://rhislop3.com/friday-feature-quality-and-the-revenue-connection-2019-version/) - I've written a lot over the years about understanding the unique connection between quality care and the systems to support its delivery, and revenue. Arguably, the most successful provider organizations understand that impeccable quality of care (delivery, outcomes, patient satisfaction) begets high occupancy (referrals) and preferential payer mix (quality mix). Of course, the inverse relationship
- [Medicare Advantage vs Traditional Medicare](https://rhislop3.com/medicare-advantage-vs-traditional-medicare/) - Medicare Advantage vs traditional Medicare is reshaping networks, payments, and risk for providers, senior living leaders, and policymakers nationwide.
- [The Future of Healthcare Reimbursement Models](https://rhislop3.com/the-future-of-healthcare-reimbursement-models/) - The future of healthcare reimbursement models will reward measurable outcomes, strong data, and care coordination while exposing weak operating models.
- [Update: Medicare Advantage Prior Authorization](https://rhislop3.com/update-medicare-advantage-prior-authorization/) - A review of Medicare Advantage prior authorization, what federal oversight has changed, and why operators still face administrative and revenue risk now.
- [How Reimbursement Cuts Affect Margins](https://rhislop3.com/how-reimbursement-cuts-affect-margins/) - Learn how reimbursement cuts affect margins in post-acute care, from fixed costs and labor pressure to service-line decisions and strategic responses.
- [CMS Defer $1B in Medicaid Payments to CA, MN](https://rhislop3.com/cms-defer-1b-in-medicaid-payments-to-ca-mn/) - CMS withholds $1B in Medicaid payments from California and Minnesota, exposing how eligibility controls, cash flow, and federalism collide directly.
- [Fee for Service vs Value Based Care](https://rhislop3.com/fee-for-service-vs-value-based-care/) - Fee for service vs value based care changes who carries risk, how providers are paid, and what senior care leaders must build for the next cycle of care.
- [CMS Changes SNF Surveys With New Risk Surveys](https://rhislop3.com/cms-changes-snf-surveys-with-new-risk-surveys/) - CMS modernizes nursing home oversight with new risk-based survey approach, shifting federal scrutiny toward facilities where resident harm is most likely.
- [Why Rural Health Transformation Matters](https://rhislop3.com/why-rural-health-transformation-matters/) - A rural health transformation program can stabilize access, align payment, and reshape care delivery for providers facing margin and workforce strain.
- [Life Plan Community Economics Explained](https://rhislop3.com/life-plan-community-economics-explained/) - A life plan community can look stable from the outside - full campus, strong reputation, long wait list history, predictable monthly fees. Then interest rates move, labor costs stay elevated, refund obligations come due, and the balance sheet tells a harder story. That is why life plan community economics deserve closer attention than many boards,
- [7 Top Healthcare Policy Risks 2026](https://rhislop3.com/7-top-healthcare-policy-risks-2026/) - A sharp look at top healthcare policy risks 2026, from Medicare cuts and MA scrutiny to labor, oversight, and capital pressure.
- [Update on Medicare Site-Neutral Payments](https://rhislop3.com/update-on-medicare-site-neutral-payments/) - A guide to Medicare site-neutral payments for healthcare leaders: the policy, financial exposure, and operating decisions that could reshape care delivery.
- [Post Acute Care Compliance Checklist for 2026](https://rhislop3.com/post-acute-care-compliance-checklist-for-2026/) - Use this post acute care compliance checklist to align governance, billing, quality, referrals, privacy, and audit readiness across your organization.
- [Healthcare Economics Trends 2026](https://rhislop3.com/healthcare-economics-trends-2026/) - Healthcare economics trends 2026 will reshape reimbursement, labor, capital, and care delivery. Here's what operators and investors should watch.
- [What CMS Medicare Regulatory Relief Signals](https://rhislop3.com/what-cms-medicare-regulatory-relief-signals/) - What the https://www.cms.gov/medicare-regulatory-relief-rfi means for providers, operators, and investors facing Medicare policy pressure.
- [Medicare Hospice Fraud Is a Policy Failure](https://rhislop3.com/medicare-hospice-fraud-is-a-policy-failure/) - Medicare hospice fraud reflects weak oversight, distorted incentives, and rising compliance risk for operators, investors, and policymakers.
- [Federal Healthcare Policy Updates in Focus](https://rhislop3.com/federal-healthcare-policy-updates-in-focus/) - Federal healthcare policy updates are reshaping reimbursement, oversight, and strategy for providers, investors, and senior care operators.
- [The Challenge of Medicare Insolvency](https://rhislop3.com/the-challenge-of-medicare-insolvency/) - Medicare insolvency projections shape provider strategy, payment risk, and policy debate. Here’s what healthcare leaders should watch next.
- [Private Equity in Healthcare: What Changes Now](https://rhislop3.com/private-equity-in-healthcare-what-changes-now/) - Private equity in healthcare is no longer a niche financing story. It is now a governance story, a labor story, a reimbursement story, and increasingly a political story. For operators and investors alike, the real question is not whether private equity belongs in healthcare, but what kind of behavior the market and regulators will tolerate
- [Home Health Compliance Updates That Matter](https://rhislop3.com/home-health-compliance-updates-that-matter/) - A home health agency can miss its numbers for a quarter and recover. It can miss a key compliance signal and spend the next year dealing with repayments, audits, and reputational damage. That is why home health compliance updates deserve executive attention well beyond the compliance department. What has changed is not simply the volume of regulation.
- [Post Acute Care Strategy That Holds Up](https://rhislop3.com/post-acute-care-strategy-that-holds-up/) - A weak discharge network is no longer a referral problem. It is a margin problem, a compliance problem, and increasingly a reputation problem. That is why post acute care strategy now sits much closer to the center of health system planning, Medicare Advantage contracting, and operator survival than many organizations want to admit. For years,
- [Hospice Regulatory Changes 2026 Explained](https://rhislop3.com/hospice-regulatory-changes-2026-explained/) - A hospice operator can absorb only so many moving targets at once. Wage pressure is still real, referral patterns remain fragile, and Medicare oversight is getting sharper, not softer. Against that backdrop, hospice regulatory changes 2026 are not just another annual compliance update. They are part of a broader federal posture that is more skeptical
- [Senior Living Occupancy Trends in 2026](https://rhislop3.com/senior-living-occupancy-trends-in-2026/) - This post is a deeper look at the global trends of senior living census trends, following up on an earlier post (https://rhislop3.com/mid-year-senior-living-update/) The recovery story in senior housing is no longer about whether occupancy is coming back. It is about what kind of demand is returning, which operators can convert it, and how long margin
- [Medicare Reform Analysis Update](https://rhislop3.com/medicare-reform-analysis-update/) - The real Medicare reimbursement reform analysis starts with a hard truth: this is no longer a debate about payment mechanics. It is a debate about who absorbs risk, which care settings remain financially viable, and whether federal policy can restrain spending without destabilizing access. For operators in post-acute care, senior living, home health, hospice, and
- [Presentation: Medicare is Bankrupting America](https://rhislop3.com/presentation-medicare-is-bankrupting-america/) - A couple of weeks ago, I did a webinar for Freedom Hub titled Medicare is Bankrupting America. The Power Point is available for download, in this post.
- [Private Equity Ownership Scrutiny](https://rhislop3.com/private-equity-ownership-scrutiny/) - Private equity investment and ownership in healthcare businesses has been a frequent topic in the news, with coverage largely focusing on the negative aspects.
- [Legislation Restricting PE Role in Healthcare](https://rhislop3.com/legislation-restricting-pe-role-in-healthcare/) - This post includes a fairly complete look at legislation that has been introduced since 2023, targeting PE ownership and investment in healthcare companies.
- [Agency Scrutiny of PE in Healthcare](https://rhislop3.com/agency-scrutiny-of-pe-in-healthcare/) - With PE scrutiny begetting legislation happening, equal activity regarding PE investment in healthcare is moving and has moved at the agency level (e.g., FTC).
- [CMS: Moratorium on Hospices and Home Health](https://rhislop3.com/cms-moratorium-on-hospices-and-home-health/) - On May 13 the Centers for Medicare & Medicaid Services imposed a six-month moratorium on new Medicare enrollments for hospices and home health agencies (HHAs).
- [Mid-Year Senior Living Update](https://rhislop3.com/mid-year-senior-living-update/) - Senior Living occupancy trends are good, and the industry is faring better than it has since the Pandemic, yet development weakness persists from cost pressure.
- [Senior Living Occupancy Trends: Positive Fourth Quarter Data | National Investment Center](https://rhislop3.com/senior-living-occupancy-trends-positive-fourth-quarter-data-national-investment-center/) - Fourth quarter data is out from the National Investment Center regarding senior living/senior care occupancies and the trend remains positive. See the NIC summary here: 4Q23-NIC-MAP-Market-Fundamentals-PDF Senior Housing occupancy, 4th quarter, came in at 85.1%, up 80 basis points from the 3rd quarter. Nursing home/SNF occupancy rose to 83.1%, up 70 basis points. Assisted Living
- [2024 Senior Living Outlook Report](https://rhislop3.com/2024-senior-living-outlook-report/) - Senior Housing News and Lument conducted a survey (November of 2023) of senior living organizations and executives regarding their outlook for 2024. They consolidated the responses into a report. That report is available here: 2024-shn-lument-outlooksurveyreport-vf.original The highlights from the report are below. The general consensus of respondents was a positive outlook (87%) for 2024, buffered mostly
- [Wednesday Feature: Framework for Improved Staffing Levels](https://rhislop3.com/wednesday-feature-framework-for-improved-staffing-levels/) - Happy Hump Day! Wow, winter has really settled in for most of the U.S. - cold and snow as far south as Arkansas and cold, almost everywhere. Next week looks a bit more promising, weather-wise. Staffing for all providers is a major issue. For rural facilities, it can be the difference between staying afloat or closing. I
- [Conference Board Report/C-Suite Outook for 2024: Concerns Ahead](https://rhislop3.com/conference-board-report-c-suite-outook-for-2024-concerns-ahead/) - The Conference Board, a renowned non-profit research organization, has recently released a comprehensive report that sheds light on the business outlook and concerns of CEOs for the year 2024. This study offers valuable insights into the minds of top executives, highlighting their attention towards the economy and organizational talent. In this post, I'll delve into
- [The Cost of Assisted Living: A Report from Seniorly](https://rhislop3.com/the-cost-of-assisted-living-a-report-from-seniorly/) - Over the years I have written many articles about the cost of healthcare and in particular, the cost of senior living and senior healthcare. As the population ages, the demand for senior living and care expands. Per the U.S. Census Bureau, the U.S. population age 65 and over grew nearly five times faster than the
- [Iowa Lawsuit = More Bad News for Assisted Living](https://rhislop3.com/iowa-lawsuit-more-bad-news-for-assisted-living/) - In January of 2022, a resident with dementia wandered out of her Assisted Living Memory Care facility in Iowa and ultimately, froze to death. The State of Iowa investigation uncovered that the resident wandered outside of the building at 9:30 p.m. the previous night. Her absence went unnoticed for eight hours plus even though the alarm
- [Why Managers Need to Shift Focus from Putting Out Fires to Empowering Their Teams](https://rhislop3.com/why-managers-need-to-shift-focus-from-putting-out-fires-to-empowering-their-teams/) - In my reading stack this weekend (ok, virtual stack), I came across a number of articles on leadership and management. Some were good, some were not, and lots were focused on "old" issues and problems. One in particular, caught my attention - "Management as We Know it Is Broken: How can Leaders Fix It?" What
- [Unlocking the Potential: Overcoming Challenges for LTPAC Providers in ACO Participation](https://rhislop3.com/unlocking-the-potential-overcoming-challenges-for-ltpac-providers-in-aco-participation/) - Yesterday, the American Health Care Association and the National Center for Assisted Living plus the National Assocation of ACOs released a white paper that includes a set of recommendations for CMS, designed to increase the participation of long term and post-acute care (LTPAC) providers in accountable care organizations (ACOs). The white paper is available here: AHCA
- [Wednesday Feature: Lending Trends Still Reflecting a Tight Capital Environment](https://rhislop3.com/wednesday-feature-lending-trends-still-reflecting-a-tight-capital-environment/) - Happy Hump Day! The National Investment Center released its third quarter 2023 lending trends report and while the data is a bit old, it is reflective of current market conditions. The report is available here: NIC_Lending__Trends_Report_3Q2023 Suffice to say since I last provided an update on this subject area, things have not improved. Capital access
- [Wednesday Feature: Massachusetts Nursing Home Residents Set to Transition to Community Living with $1 Billion Settlement](https://rhislop3.com/wednesday-feature-massachusetts-nursing-home-residents-set-to-transition-to-community-living-with-1-billion-settlement/) - Happy Hump Day! Last week, the Lieutenant Governor of Massachusetts, Kim Driscoll, announced the settlement of a class action lawsuit filed against the state by six disabled nursing home residents. The suit was filed in 2022 alleging that the state underfunded community-based care options, trapping them in nursing homes despite their wishes to return to
- [Analyzing the 2023 Cost of Care Survey: Trends in Long-Term Care Rate Increases](https://rhislop3.com/analyzing-the-2023-cost-of-care-survey-trends-in-long-term-care-rate-increases/) - On Tuesday, the Genworth 2023 Cost of Care Survey was released. Year-over-year rate increases in long-term care/senior living ranged from 1% to 10%, depending on the setting (SNF, Assisted Living, etc.). The report is available here: Genworth Cost of Care 2023 The report is interesting though in some ways, a bit misleading as data is
- [Senior Living Rate Increases are Slowing: Revenue Diversification Offers Opportunities](https://rhislop3.com/senior-living-rate-increases-are-slowing-revenue-diversification-offers-opportunities/) - Discover how slowing rate increases in senior living impact revenue, and how revenue diversification can help meet resident service demands and grow revenue.
- [Private Equity Investment in Nursing Home Sector Generates Regulatory Scrutiny](https://rhislop3.com/private-equity-investment-in-nursing-home-sector-generates-regulatory-scrutiny/) - Updates on the latest regulatory activities in Congress regarding private equity investment in the nursing home sector and post-acute sector.
- [Arbitration Agreements: AZ Atty. General Seeks to End Secrecy Provisions](https://rhislop3.com/arbitration-agreements-az-atty-general-seeks-to-end-secrecy-provisions/) - Arizona Attorney is challenging nursing home companies like The Ensign Group to end secrecy surrounding abuse and neglect with nursing arbitration agreements.
- [Senior Living Occupancy Up: Challenges Remain](https://rhislop3.com/senior-living-occupancy-up-challenges-remain/) - Data released by NIC (National Investment Center) show senior living occupancies continue to tick up. Despite the increase, challenges for full recovery exist.
- [Senior Housing and Care M&A at Record Level](https://rhislop3.com/senior-housing-and-care-ma-at-record-level/) - M&A activity in the seniors housing and care sector set a quarterly record with 183 announced transactions. This is a 21% increase from the first quarter.
- [Senior Living Liability Claims Analysis Report](https://rhislop3.com/senior-living-liability-claims-analysis-report/) - Marsh, the world's largest insurance broker, released its 2024 Senior Living Liability Claims Analysis Report last week, detailing claim costs and sources.
- [Federal Assisted Living Regulatory Initiative](https://rhislop3.com/federal-assisted-living-regulatory-initiative/) - Last week via a news release, the specter of federalized Assisted Living became real. Per this news, legislation to create a federal framework is forthcoming.
- [Medicare's Prescription Drug Price Two-Step](https://rhislop3.com/medicares-prescription-drug-price-two-step/) - Medicare prescription drug price savings has turned into a political two-step with the administration subsidizing insurers to keep Part D premiums from surging.
- [Merger/Affiliation Strategy Update - Checklist](https://rhislop3.com/merger-affiliation-strategy-update-checklist/) - As a follow-up to a post from last year, the drivers for mergers/affiliations remain similar and in turn, a strategy update and checklist are warranted.
- [Senior Housing Marketing and Outlook](https://rhislop3.com/senior-housing-marketing-and-outlook/) - At the final quarter of the year, it's time to examine the current trends in senior housing from marketing to occupancy plus the outlook for 2025.
- [Marketing: Value Propositions and Strategy](https://rhislop3.com/marketing-value-propositions-and-strategy/) - In a recent post (Tuesday) regarding senior housing marketing, I referenced the importance in strategy, of developing and communicating a value proposition.
- [Illinois Assisted Living and COVID Immunity](https://rhislop3.com/illinois-assisted-living-and-covid-immunity/) - The Illinois Supreme Court just issued a ruling regarding healthcare providers (Assisted Living included) and immunity against negligence claims during COVID.
- [Touching Base with 2024's Outlook](https://rhislop3.com/touching-base-with-2024s-outlook/) - In December of 2023 (late), I wrote a post with my 2024 Outlook. I dusted off the "old" crystal ball and made some predictions. Time to touch base on how I did.
- [Litigation Breaks on CMS Staffing Mandate](https://rhislop3.com/litigation-breaks-on-cms-staffing-mandate/) - Litigation has started in Federal courts, challenging CMS' SNF "staffing mandate". An impetus behind the challenges to the mandate is SCOTUS' Chevron decision.
- [SNF Survey and Certification Update](https://rhislop3.com/snf-survey-and-certification-update/) - In the 2025 Final Rule, CMS changed how surveyors can impute fines, creating a layered effect (per instance and per day, both enforced during the same survey).
- [CMS Releases Home Health Final Rule 2025](https://rhislop3.com/cms-releases-home-health-final-rule-2025/) - On November 1, 2024, CMS issued the 2025 Home Health PPS final rule, which updates Medicare payment policies and rates for Home Health Agencies.
- [Oxford Valley Health v. Nursa Update](https://rhislop3.com/oxford-valley-health-v-nursa-update/) - Nursa, a Utah staffing company, sued Oxford Valley Health in US District Court, for $4.2 million in nurse placement fees and $781,000 in late payment fees.
- [CCRCs (Life Plan): Econ Data in Marketing?](https://rhislop3.com/ccrcs-life-plan-econ-data-in-marketing/) - In a time of changing markets, using economic data can provide a large advantage in crafting specific messages and strategies to generate new customers.
- [CMS Reinforces Hospice Regulatory, Fraud Focus](https://rhislop3.com/cms-reinforces-hospice-regulatory-fraud-focus/) - A Memo from yesterday was sent to remind survey agencies of CMS' intent to detect and pursue fraud in Hospice, using the survey process as a tool for detection.
- [Twofer Tuesday: Marketing Insights for 2025](https://rhislop3.com/twofer-tuesday-marketing-insights-for-2025/) - The bifurcated title means two subjects, wrapped into a "what's next" for 2025. The wrapper in this case is marketing, from pricing to trends plus outlooks.
- [Friday Feature: Four Topics to Watch](https://rhislop3.com/friday-feature-four-topics-to-watch/) - Off a busy week and into a holiday week (Thanksgiving) I thought a post sharing my top four health policy topics to watch made sense.
- [Being a More Effective Executive: A Checklist](https://rhislop3.com/being-a-more-effective-executive-a-checklist/) - Building a high performing organization is about creating effective leaders and leadership habits that lead to building effective systems and structures.
- [CMS Issues Updates on Immediate Jeopardy](https://rhislop3.com/cms-issues-updates-on-immediate-jeopardy/) - In 2019 CMS made revisions to Appendix Q, State Operations Manual applicable to Immediate Jeopardy definitions. CMS just made updates to those IJ guidelines.
- [Life Expectancy Falls Behind the World](https://rhislop3.com/life-expectancy-falls-behind-the-world/) - A study from the Insitute of Health Metrics and Evaluation (IHME), concluded that the U.S. life expectancy will rise a touch by 2050 but lag much of the world.
- [Senior Living Capital Outlook 2025](https://rhislop3.com/senior-living-capital-outlook-2025/) - This early, forecasting twelve months with respect to capital markets is like forecasting the next year's baseball season and World Series - an educated guess.
- [A Population Peek at Housing Demand](https://rhislop3.com/a-population-peek-at-housing-demand/) - A trend I have followed for some time is the shift in demographics specifically, the growth in seniors plus a fall in birthrate and what this means for housing
- [InnovAge Fraud Litigation Expands](https://rhislop3.com/innovage-fraud-litigation-expands/) - A Colorado federal judge certified a class of investors in a suit against InnovAge claiming the company made false statements in an IPO causing investment loss.
- [Fixing Healthcare Spending in the U.S.](https://rhislop3.com/fixing-healthcare-spending-in-the-u-s/) - A significant driver of federal spending is healthcare spending. The U.S. spends more on healthcare than any other country. Too much is inefficient spending.
- [DOJ Recovers $2.9 Billion in Fraud in 2024](https://rhislop3.com/doj-recovers-2-9-billion-in-fraud-in-2024/) - The Department of Justice (DOJ) announced the recovery of $2.9 billion in federal False Claims Act violations (fraud) for 2024 -fiscal year ending September 30
- [Doc Payment Fix Bill in the Works?](https://rhislop3.com/doc-payment-fix-bill-in-the-works/) - A bipartisan group of House members introduced legislation addressing a pay cut for doctors and other providers that took effect at the start of the year.
- [Medicaid Spending in the DOGE Radar](https://rhislop3.com/medicaid-spending-in-the-doge-radar/) - Elon Musk and DOGE have requested access to CMS data encompassing over $1 trillion in annual payments. Within focus for spending reduction is Medicaid.
- [Rural Healthcare Under Intense Pressure](https://rhislop3.com/rural-healthcare-under-intense-pressure/) - According to a recent report, 432 rural hospitals are at risk of closure. Top indicators are Medicaid expansion status and years of negative operating margin.
- [Life Plan/IL Challenges Ahead?](https://rhislop3.com/life-plan-il-challenges-ahead/) - For years, a theory of a "silver tsunami", an influx of older homeowners, would flood the market with listings. The new trend looks more "aging in-place".
- [House GOP Releases Budget Blueprint for Savings](https://rhislop3.com/house-gop-releases-budget-blueprint-for-savings/) - House Republicans released a budget blueprint last week with the goal of achieving spending reductions oof $880 billion from Medicare and Medicaid.
- [Medicare Hospice and Home Health Fraud, Part 1](https://rhislop3.com/medicare-hospice-and-home-health-fraud-part-1/) - Medicare home health and hospice billing fraud has emerged as a serious issue within the U.S. healthcare system, costing taxpayers billions of dollars annually.
- [Medicare Hospice and Home Health Fraud, Part 2](https://rhislop3.com/medicare-hospice-and-home-health-fraud-part-2/) - Medicare home health and hospice fraud has emerged as a significant issue in U.S. healthcare, costing taxpayers billions of dollars. This is part 2 of 3 parts.
- [Medicare Hospice and Home Health Fraud, Part 3](https://rhislop3.com/medicare-hospice-and-home-health-fraud-part-3/) - This is part three of the series of posts on hospice and home health fraud. The focus is on specific cases of fraud and the regulatory activity to detect fraud.
- [Medicaid Spending Reductions, Part II](https://rhislop3.com/medicaid-spending-reductions-part-ii/) - This is Part II of a series I wrote on Medicaid cuts. With healthcare spending a major political issue, I hope these posts provide a debate context for readers.
- [Medicaid Spending Reductions, Part III](https://rhislop3.com/medicaid-spending-reductions-part-iii/) - This is part three of a series I wrote on Medicaid spending reductions. Recent Republican budgets target Medicaid for $800 plus billion in spending reductions.
- [Clicks and Coffee Podcast](https://rhislop3.com/clicks-and-coffee-podcast/) - A few weeks back, I joined Alexander Burkhardt from Pantelope for a podcast discussion on healthcare and senior living trends, plus some outlooks (forward).
- [Podcast on Healthcare Spending and Reform](https://rhislop3.com/podcast-on-healthcare-spending-and-reform/) - My podcast visit with Daniel Horowitz on healthcare reform, healthcare spending, health policy, economics and a bit of the future in terms of reform.
- [VOHRA Wound Care Faces Medicare Fraud Claim](https://rhislop3.com/vohra-wound-care-faces-medicare-fraud-claim/) - The U.S. Department of Justice filed a False Claims Act suit against Vohra Wound Physicians alleging engagement in a nationwide scheme to defraud Medicare
- [Republican House Medicaid Reform Package](https://rhislop3.com/republican-house-medicaid-reform-package/) - On May 11, House Republicans introduced a 160-page bill, part of a broader budget reconciliation package, seeking to cut billions in federal Medicaid spending.
- [CMS Releases Strategy on MAHA](https://rhislop3.com/cms-releases-strategy-on-maha/) - The CMS 2025 strategy aligns with the "Make America Healthy Again" (MAHA), focused on prevention, patient empowerment, and competition to transform healthcare.
- [Tough Housing Market = Life Plan Challenges](https://rhislop3.com/tough-housing-market-life-plan-challenges/) - There is a direct connection that Life Plan/CCRC organizations have with the real estate market. This post discusses real estate sales challenges and CCRCS.
- [CPI and Healthcare Inflation](https://rhislop3.com/cpi-and-healthcare-inflation/) - Last week, BLS released May's CPI report. Overall inflation is cooling, but healthcare costs still run hotter. This is the how healthcare prices are calculated.
- [Congress, Medicaid Subsidies - What's Next](https://rhislop3.com/congress-medicaid-subsidies-whats-next/) - The Senate and soon the House will approve a resolution to keep the government open through January 30; decisions about the ACA subsidies wait until December.
- [Shutdown is Over: The Pieces](https://rhislop3.com/shutdown-is-over-the-pieces/) - Despite the end of the shutdown, pivotal issues— the future of enhanced premium tax credits under the Affordable Care Act (ACA), remain—until at least December.
- [Hospital-at-Home Waiver Ended - What Next?](https://rhislop3.com/hospital-at-home-waiver-ended-what-next/) - The bill that ended the government shutdown extended the Medicare Hospital at Home program, to January 30, 2026. The question: What (happens) next?
- [Medicare Hospice TPE Basics and Update](https://rhislop3.com/medicare-hospice-tpe-basics-and-update/) - Recently, I've discussed and reviewed, the ongoing Medicare TPE program with a number of hospices. Many questions still exist about process and claim denials.
- [The ACA Subsidies: Where we Are, What's Next](https://rhislop3.com/the-aca-subsidies-where-we-are-whats-next/) - The Senate rejected two bills to addressing ACA subsidies, a Democratic bill to extend the subsidies and a Republican bill involving Health Savings Accounts.
- [Real Estate Market and Sr. Living Update](https://rhislop3.com/real-estate-market-and-sr-living-update/) - The residential real estate market deeply influences senior living sales (leasing or selling units in senior living communities, driving occupancy and revenue.
- [Rural Healthcare Still Struggling](https://rhislop3.com/rural-healthcare-still-struggling/) - Seven hundred fifty-six rural hospitals in the United States are at risk of closure due to financial instability, with over 40% classified "at immediate risk".
- [Site Neutral Payments Kick-0ff!](https://rhislop3.com/site-neutral-payments-kick-0ff/) - On January 1, 2026, Medicare’s site-neutral payment began with drug infusion services such as chemotherapy and infusion therapy in non-hospital campus settings.
- [Podcast: Why Both Parties Suck on Healthcare](https://rhislop3.com/podcast-why-both-parties-suck-on-healthcare/) - Last month I joined Dan Horowitz's show to provide a plan and a vision on the most important economic and fiscal issues...ACA and healthcare reform.
- [Trump's Healthcare Policy Plan: A Review](https://rhislop3.com/trumps-healthcare-policy-plan-a-review/) - On January 15, the Trump healthcare policy framework containing several significant proposals was released. The plan includes changes but is absent in details.
- [Rural Health Transformation Program Overview](https://rhislop3.com/rural-health-transformation-program-overview/) - The Rural Health Transformation Program was initiated to mitigate the effects of Medicaid cuts under OBBB. This post covers policy structure and current status.
- [Medicare is Bankrupting America](https://rhislop3.com/medicare-is-bankrupting-america/) - Medicare is Bankrupting America webinar, covering program financial condition and opportunities for reform February 18, 2026.
- [Program: Medicare is Bankrupting America](https://rhislop3.com/program-medicare-is-bankrupting-america/) - Last week I had the chance to work with Freedom Hub on a program called Medicare is Bankrupting America. The program is now available to watch on Rumble or X.
- [Private Equity Update - Regulation](https://rhislop3.com/private-equity-update-regulation/) - Recently, I wrote a post on federal legislative activity to impose regulation on Private Equity investment in senior living. This post updates that post.
- [Real Estate Sales Report - News Worsens for CCRCs/Life Plan Communities](https://rhislop3.com/real-estate-sales-report-news-worsens-for-ccrcs-life-plan-communities/) - With occupancy rebounding to pre-pandemic levels and demand remaining strong, CCRCs/Life Plan Communities continue to face economic headwinds from capitalizing on improving market conditions. Capital costs continue to rise making borrowing money a challenge or alternatively, perhaps adding additional debt service costs if existing debt is variable. Accessing capital is nearly imperative for most CCRCs/Life
- [Medicaid Spending Reductions: What to Know](https://rhislop3.com/medicaid-spending-reductions-what-to-know/) - Medicaid spending cuts have been in the news, on the passage of the Republican Continuing (spending) Resolution. This is Part I of a series on Medicaid reform.
- [Check: Medicare Advantage Coverage Issues](https://rhislop3.com/check-medicare-advantage-coverage-issues/) - Between providers and patients, coverage issues have increased as enrollment has grown (about 1 in 2 Medicare beneficiaries is in a Medicare Advantage plan).
- [Rural Hospital Program: Extra Cash for Emergency and Outpatient Services Stuck in Neutral](https://rhislop3.com/rural-hospital-program-extra-cash-for-emergency-and-outpatient-services-stuck-in-neutral/) - REHs (Rural Emergency Hospitals) were created to improve and increase, access to emergency services and ideally, expanded outpatient services in rural areas.
- [Friday Feature: Important COVID Criminal Case Dismissed](https://rhislop3.com/friday-feature-important-covid-criminal-case-dismissed/) - Ten days ago, I wrote a post about COVID litigation and how it was not only mounting but also morphing in terms of scope. Cases were predominantly focused on responsibility for infections at the senior living end such as, my 'family member' caught COVID at XYZ Manor and died, so therefore XYZ Manor is responsible
- [Rising Health Care Costs - A Serious Issue, Election Implications?](https://rhislop3.com/rising-health-care-costs-a-serious-issue-election-implications/) - Long time readers/followers know that I from time to time, address health care costs. I follow economics generally and write about the same, especially when there are intersectional issues to address. As we are heading into a presidential election cycle (we are in the early innings) and, issues like health care costs in this country
- [CMS Offers Fix to Medicare Advantage Denials](https://rhislop3.com/cms-offers-fix-to-medicare-advantage-denials/) - An issue that has been tied to AI (artificial intelligence) and specifically, to Medicare Advantage plans, involves coverage denials. I wrote about this in a post earlier this year at https://rhislop3.com/2023/05/01/medicare-advantage-part-d-final-rule/ Coverage denials have been a fairly hot topic around Medicare Advantage plans. The core of the issue is that Medicare Advantage plans are required
- [Non-Profit Ownership/Sponsorship Changes Moving at Record Pace](https://rhislop3.com/non-profit-ownership-sponsorship-changes-moving-at-record-pace/) - While mergers and acquisitions are generally down, affiliations, closings in some cases, and sponsorship changes in non-profit senior living and care are at a record pace. Back in July, I wrote about the disconnect between acquisitions and the merger/affiliation changes occurring among non-profits. That post is here: https://rhislop3.com/2023/07/24/senior-living-and-care-ma-two-worlds/ A news release from Ziegler Investment Banking,
- [The Debate: Policy that Should be Discussed](https://rhislop3.com/the-debate-policy-that-should-be-discussed/) - Tonight's presidential debate is ninety minutes and no doubt, full of discussion. There are a ton of policy issues that should be discussed, but many, won't be.
- [Senior Living/CCRC Risk Reduction and the Fair Housing Act](https://rhislop3.com/senior-living-ccrc-risk-reduction-and-the-fair-housing-act/) - On Friday, I wrote about expanding litigation due to increasing resident care needs found in senior living, assisted and independent living. Specifically, the issue is primarily around "acuity creep" or residents aging in-place, in environments that may not have the staff and infrastructure to meet their advancing care needs. Friday's post is here: https://rhislop3.com/2023/12/01/friday-feature-senior-living-litigation-watch-risks-at-ccrcs-independent-living/ I've
- [JAMA Study: Private Equity Ownership and Hospital Outcomes](https://rhislop3.com/jama-study-private-equity-ownership-and-hospital-outcomes/) - Happy 2024! I trust everyone had a blessed and happy holiday season and rang in the New Year with joy and optimism. Across the last two months of 2023, JAMA (Journal of American Medical Association) has published two studies on private equity ownership in healthcare, specifically in hospitals and SNFs. Not to accuse JAMA of having
- [Wednesday Feature: Dying Broke](https://rhislop3.com/wednesday-feature-dying-broke/) - Happy First Hump Day of 2024! Short weeks aren't really deserving of a Hump Day, but it is officially a Wednesday that is not a holiday in a workweek (though I'm sure many are still off from the Christmas/New Year's season). Thus, no matter deserved or not, it is my first Wednesday Feature and therefore,
- [My Notebook: Econ Tuesday Recap](https://rhislop3.com/my-notebook-econ-tuesday-recap/) - Working on a number of things today with other projects in the fire as well. Haven't had much time to sit and think, let alone compose much of a post or do much research into current topics so this quicky via the notebook will have to do - Happy TGIF Eve! Tuesday's CPI report and
- [The Financial Struggle of Rural Hospitals: A Growing Concern for Healthcare Access](https://rhislop3.com/the-financial-struggle-of-rural-hospitals-a-growing-concern-for-healthcare-access/) - Among the many healthcare sectors I follow, rural healthcare has become my favorite. Oddly enough, it's not because of the policy issues that exist, though it should be. It is because it is an overlooked sector and one that has a real risk of collapse. Last summer (2023) I wrote a post about the plight
- [Hospice 2025 Final Rule, 2.9% Increase](https://rhislop3.com/hospice-2025-final-rule-2-9-increase/) - The CMS issued the 2025 Hospice Final Rule, with a 2.9% increase in per diem payments plus new quality reporting measures.
- [The Politics of Population and Immigration](https://rhislop3.com/the-politics-of-population-and-immigration/) - As a society, we have an entitlement problem that is growing out of control, and it is uniquely tied to the politics of population and immigration.
- [Hospice Fraud and Abuse Front and Center](https://rhislop3.com/hospice-fraud-and-abuse-front-and-center/) - Recent cases of hospice fraud and abuse involving improper billing to Medicare have put the industry front and center again in terms of compliance challenges.
- [Management Can Prevent Turnover](https://rhislop3.com/management-can-prevent-turnover/) - Per Gallup, 42% of employees who left their jobs believe management could have prevented their turnover. In May, 51% of all workers were looking for new jobs.
- [Kamala Harris "Likely" Health Policy](https://rhislop3.com/kamala-harris-likely-health-policy/) - Now likely that Kamala Harris will be the Democrat Presidential candidate, a look at her stance on various issues healthcare aka, her health policy, is timely.
- [Compliance: Develop a Culture of Disclosure](https://rhislop3.com/compliance-develop-a-culture-of-disclosure/) - Developing a culture of transparency that promotes and sustains disclosure (speaking up) can yield advantages beyond merely decreasing misconduct.
- [Geriatrician Shortage = Cause for Concern](https://rhislop3.com/geriatrician-shortage-cause-for-concern/) - There are 7,500 licensed geriatricians in the U.S., 1 per 8,267 seniors. The number specializing in geriatrics is not keeping pace and is a cause for concern.
- [Phantom Diseases and Medicare Advantage Fraud](https://rhislop3.com/phantom-diseases-and-medicare-advantage-fraud/) - Medicare Advantage plans are using home nurse visits to identify possible or questionable diseases conditions (so called, phantom diseases) via screenings.
- [Nursing Home Closures Creating Access Issues](https://rhislop3.com/nursing-home-closures-creating-access-issues/) - With increasing senior demand for hospital care, an ongoing wave of nursing home closures is creating post-acute access issues. Since 2020, 774 homes closed.
- [Private Equity and Hospital Assets](https://rhislop3.com/private-equity-and-hospital-assets/) - Per a JAMA study, private equity firms invested $505 billion in hospitals between 2018 to 2023. The study points to negative asset changes post-acquisition.
- [Final 2025 SNF Rule - Rate Increase, More Fines](https://rhislop3.com/final-2025-snf-rule-rate-increase-more-fines/) - Under the Final 2025 SNF Rule released last Wednesday, nursing homes are set to receive a 4.2% rate increase plus a stricter enforcement system (more fines).
- [Donald Trump "Likely" Health Policy](https://rhislop3.com/donald-trump-likely-health-policy/) - Today, with the election getting close (less than 70 days out), it's an opportune time to look at Donald Trump's likely health policy positions.
- [Senior Living Bankruptcy Trend Remains Alarming](https://rhislop3.com/senior-living-bankruptcy-trend-remains-alarming/) - The healthcare sector experienced another quarter of record-high distress levels and bankruptcies. This bankruptcy trend for senior living remains alarming.
- [Senior Living Marketing Update](https://rhislop3.com/senior-living-marketing-update/) - As summer begins to wind down, I figured an update on senior living marketing (rates, incentives, referrals, resident movement) was in order.
- [TEAM Model and Post-Acute Care](https://rhislop3.com/team-model-and-post-acute-care/) - The value-based care TEAM model (participation) is mandatory for selected hospitals and "optional" for post-acute care providers, starting January 2026.
- [Fitch Non-Profit CCRC Ratings Update](https://rhislop3.com/fitch-non-profit-ccrc-ratings-update/) - Fitch Ratings completed updates to its ratings criteria for non-profit (CCRCs), enhancing the reflection of the risk profile for these rated entities.
- [Eighteen CCRCs Impacted by Fitch Ratings Update](https://rhislop3.com/eighteen-ccrcs-impacted-by-fitch-ratings-update/) - What has occurred as a result of a recent Fitch Ratings Update is that eighteen CCRCs have been impacted, falling into a status of "Under Criteria Observation".
- [Exploring Age-Friendly Healthcare Programs](https://rhislop3.com/exploring-age-friendly-healthcare-programs/) - The ACHC launched two new credentials for home care and hospice, exploring the framework of the Age-Friendly Healthcare program in real-world home settings.
- [Healthcare Fraud is Rampant and so are Costs](https://rhislop3.com/healthcare-fraud-is-rampant-and-so-are-costs/) - The exponential growth of healthcare costs continues at rates beyond inflation. Cost growth in programs like Medicare is rampant but then again, so is fraud.
- [Nursing Assistants = Supply Shortage](https://rhislop3.com/nursing-assistants-supply-shortage/) - Nursing assistants will experience the largest projected shortfall among all healthcare occupations, with an expected shortage of 73,000 assistants by 2028.
- [Innovation: Think Inside the Box](https://rhislop3.com/innovation-think-inside-the-box/) - Many will say innovation comes from thinking outside of the box. I am, however, a believer that often, the best innovation comes from "thinking inside the box"
- [Doc Payment Fix in the Works?](https://rhislop3.com/doc-payment-fix-in-the-works/) - The House Ways and Means Committee is considering a markup of legislation that could alter Medicare's physician payment system putting a "doc fix" in the works.
- [Fed Rate Cut: Will it Help Providers?](https://rhislop3.com/fed-rate-cut-will-it-help-providers/) - In the many challenges providers face, higher borrowing rates (interest) is near the top. Yesterday's Fed Rate cut begs when and whether it will help providers.
- [Fitch: CCRCs and SNFs Still Staffing Challenged](https://rhislop3.com/fitch-ccrcs-and-snfs-still-staffing-challenged/) - According to a recent Fitch Ratings report, staffing levels at CCRCs and SNFs are still challenged - 5.90% lower than before the pandemic.
- [Federal Judge Key Ruling on False Claims Act](https://rhislop3.com/federal-judge-key-ruling-on-false-claims-act/) - On September 30, US District Judge Kathryn Mizelle Florida issued a key decision on the False Claims Act determining that qui tam may be unconstitutional.
- [Merge/Affiliation Strategy Update - Checklist](https://rhislop3.com/merge-affiliation-strategy-checklist/) - For non-profit organizations, especially with older facilities and significant leverage/floating debt, affiliation or merger may be the next best strategy.
- [Staffing, Compliance, and Litigation Risk](https://rhislop3.com/staffing-compliance-and-litigation-risk/) - Not sure how many folks caught this brief article in McKnight's....The article link is just below. https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.mcknights.com%2Fnews%2Fplaintiffs-lawyers-gaining-edge-against-nursing-home-with-staffing-issues%2F%3Futm_source%3Dnewsletter%26utm_medium%3Demail%26utm_campaign%3DNWLTR_MLT_DAILYUPDATE_0329823%26hmEmail%3DIjP1GPaY%252BJ2uvsLxTJ79bVeRWY7ycbnr%26sha256email%3Daa4cb7c695037c31a216b9562788596b6fcd012145d566f31440b6fcd139c8a9&data=05%7C01%7C%7Cbc9c24d5cbe1440a07e908db314a2be7%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C638157966865063653%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=nvzAvsPBAwKo34DvYAWOf%2Fo5C0URgGaP4msv1jIubGk%3D&reserved=0 Post COVID, all of health care faced a seismic shift in staffing levels. COVID caused wide-spread disengagement in a labor force (clinical) already stressed in numbers. Retirements, especially of nurses, exploded. As COVID abated and the economy began
- [Outlook for Single Site CCRCs/Life Plan Communities](https://rhislop3.com/outlook-for-single-site-ccrcs-life-plan-communities/) - As economic conditions continue to create headwinds for senior living, I thought this post was timely. Bottom-line: I'm seeing lots of single site and even a number of multi-site, small scale organizations struggling. Depending on their markets and their debt load plus cash position, surviving as independents could be a real challenge over the upcoming
- [CMS Releases Rule on SNF Staffing Mandate](https://rhislop3.com/cms-releases-rule-on-snf-staffing-mandate/) - CMS has for years been tinkering with a staffing mandate of approximately 4 hours per day. The Proposed Rule would impute a level of 3.0 hours per resident day.
- [CMS Final SNF Staffing Rule Released](https://rhislop3.com/cms-final-snf-staffing-rule/) - Late yesterday, CMS released the draft of the Final Rule consistently defined as the "staffing mandate rule". The actual text is now public and available.
- [Home Health 2024 Final Rule Released](https://rhislop3.com/home-health-2024-final-rule/) - On November 1, CMS issued the final PPS rule for Home Health (2024). The majority of provisions especially related to payment, take effect on January 1, 2024.
- [Skilled Nursing Operator Takes Legal Action Against Staffing Platform for Alleged Overbilling](https://rhislop3.com/skilled-nursing-operator-takes-legal-action-against-staffing-platform-for-alleged-overbilling/) - About a week ago, an SNF operator dropped a lawsuit in U.S. District Court in the District of Utah against a staffing app that works like a staffing agency.
- [Senior Housing Marketing: Bumpy Road Ahead](https://rhislop3.com/senior-housing-marketing-bumpy-road-ahead/) - The trends in occupancy and marketing have shifted, largely a result of the pandemic. Occupancy is gaining though bumpy roads due to economic headwinds persist.
- [Friday Feature: Sr. Living, Health Care, and COVID Litigation](https://rhislop3.com/friday-feature-sr-living-health-care-and-covid-litigation/) - Yesterday's post was related to the beginnings of COVID, particularly the Biden Administration's pandemic response plan. Just as Biden entered office, his administration released the response plan and the post (yesterday) included a recording of a podcast I did on the plan, COVID vaccine rollouts, etc. Coming a bit closer to full circle, the pandemic
- [Friday Feature: Regulatory Shake-Up - 20 States Revamp Assisted Living Laws in 2022 - 2023](https://rhislop3.com/friday-feature-regulatory-shake-up-20-states-revamp-assisted-living-laws-in-2022-2023/) - In the evolving landscape of Assisted Living, states need to refine their regulations. Between July 2022 and July 2023, 20 states updated their AL regulations.
- [SNFs (and others), a (not good) Staffing Litigation Trend to Watch](https://rhislop3.com/snfs-and-others-a-not-good-staffing-litigation-trend-to-watch/) - It seems like I have been writing a lot on staffing issues these past few months, and I have. Staffing along with the current economy, are a Hydra today (two headed serpent), negatively impacting provider financial conditions and patient care in many forms (access, outcomes, care coordination, etc.). A few months ago, I wrote a
- [Washington Post and Assisted Living (not so good) News](https://rhislop3.com/washington-post-and-assisted-living-not-so-good-news/) - The Washington Post covered a series of graphic incidents where residents from an Assisted Living or Memory Care facility wandered and were later, found dead.
- [Record-breaking $2.7 Billion Paid by Healthcare Providers in False Claims Act Cases](https://rhislop3.com/record-breaking-2-7-billion-paid-by-healthcare-providers-in-false-claims-act-cases/) - A couple of weeks ago, on February 22nd. the Department of Justice issued its annual statement regarding False Claims Act activity in FY 2023 - ending Sept. 30.
- [The Demographic Realities of Seniors Housing and Healthcare](https://rhislop3.com/the-demographic-realities-of-seniors-housing-and-healthcare/) - As regular readers know, I speak at a number of conferences annually. Additionally, I work with financiers and investors in the space literally daily. In all my journeys and conversations, I am still faced with some major myth "debunking" about the nature of the seniors housing and healthcare demand, current. The major myth: Baby-boomers are either
- [Leadership and 1776](https://rhislop3.com/leadership-and-1776/) - Not too long ago, I had a conversation with a young, upcoming executive. I've known her for a number of years beginning when she attended a conference (and presentation) that I spoke at. She's a future "rock star" if she chooses to be (bright, well-spoken, organized, etc.). She asked me, "What's the number one thing
- [Economic Value Analysis, Value Propositions and Marketing](https://rhislop3.com/economic-value-analysis-value-propositions-and-marketing/) - Recently I gave a presentation on strategic pricing and senior housing (see Presentations page). A key theme that I often refer to centers around the "value proposition" or in other words, the concept that pricing is both monetary and non-monetary and as such, the value proposition is about not only the price but also about
- [Political Issue: Medicare Solvency](https://rhislop3.com/issue-medicare-solvency/) - With election season heating-up, I will drop some political and policy issue posts from time to time Today's political issue is Medicare solvency
- [OHSA Rules Could Impact Healthcare/Senior Living](https://rhislop3.com/ohsa-rules-could-impact-healthcare-senior-living/) - Two proposed rules from OHSA may have (likely) impact for healthcare and senior living providers. The rules are expected to be released by the end of the year.
- [Medicare Fraud: $2.75 Billion Recovered](https://rhislop3.com/medicare-fraud-2-75-billion-recovered/) - The Department of Justice released a 2024 Medicare fraud report of charges against nearly two hundred individuals, totaling $2.75 billion recovered.
- [SCOTUS Chevron Decision a Win for Healthcare](https://rhislop3.com/scotus-chevron-decision-a-win-for-healthcare/) - The Supreme Court discarded a longstanding doctrine, Chevron, granting federal agencies leeway in writing rules. Healthcare could be a big winner with reversal.
- [Altarum Report: Healthcare Spending Accelerates Between May 23 and May 24](https://rhislop3.com/altarum-report-healthcare-spending-accelerates-between-may-23-and-may-24/) - The latest Altarum data report on healthcare spending shows acceleration between May of 2023 and May of 2024. The drivers include utilization and spending.
- [Wednesday Feature: Fitch Reinforces Deteriorating Outlook for CCRCs](https://rhislop3.com/wednesday-feature-fitch-reinforces-deteriorating-outlook-for-ccrcs/) - Fitch Ratings' latest update on the CCRC sector reinforced that CCRCs are facing a negative rating outlook of deteriorating for the balance of 2024.
- [The Economy and CCRC Performance - Update](https://rhislop3.com/the-economy-and-ccrc-performance-update/) - Exploring the impact of current economic conditions on CCRC performance and rate policy decisions based on recent Federal Reserve FOMC meeting.
- [The Poem that Once was Us - Reblog](https://rhislop3.com/the-poem-that-once-was-us-reblog/) - Readers/followers of this stie know that all content on here is basically unique, except where noted, and written by me. While I do borrow/repost data, charts, etc., the stuff here is basically original. This post is my first, and maybe not my last, deviation. It was too good not to share. It comes from this
- [The Ensign Group Inc. Case Study: Nursing Home Chains Analysis](https://rhislop3.com/the-ensign-group-inc-case-study-nursing-home-chains-analysis/) - Insights into the strategies and operations of the Ensign Group Inc. in the nursing home sector plus the staffing and litigation issues facing the organization.
- [DOJ Gets Aggressive in Pursuit of Telehealth Fraud](https://rhislop3.com/doj-gets-aggressive-in-pursuit-of-telehealth-fraud/) - Learn how the controversy surrounding false claims in telehealth services is being addressed in healthcare settings, particularly via fraud pursuit by the DOJ.
- [Defend Your Long-Term Care Facility Against Litigation with Expert Data Analysis](https://rhislop3.com/defend-your-long-term-care-facility-against-litigation-with-expert-data-analysis/) - Discover how knowledge can help long-term care providers utilize complex data to protect themselves from legal challenges and negative public perception. Learn to interpret and leverage government, consumer, and provider data to effectively depict your facility.
- [Preventing Falls in Seniors: Key Interventions Revealed by JAMA Study](https://rhislop3.com/preventing-falls-in-seniors-key-interventions-revealed-by-jama-study/) - Reg's Blog Preventing Falls in Seniors: Key Interventions Revealed by JAMA Study
- [Sr. Living Capital Access Still Challenged](https://rhislop3.com/sr-living-capital-access-still-challenged/) - June 3, 2024 - Reg's Blog Sr. Living Capital Access Still Challenged rhislop3
- [Maryland SNF Class Action Suit: Nursing Home Residents Seek Mandatory Inspections](https://rhislop3.com/maryland-snf-class-action-suit-nursing-home-residents-seek-mandatory-inspections/) - Learn about the Maryland SNF class action suit filed by nursing home residents demanding annual inspections to protect against poor care. Stay informed on the latest litigation news.
- [Welcome to the Updated Reg's Blog!](https://rhislop3.com/welcome-to-the-updated-regs-blog/) - Finally, back up and ready to go. You'll notice the look and feel is different. Everything is still here, save YOU. I'll be adding the original subscriber list over the next few days. In the meantime, you can subscribe via clicking on the SUBSCRIBE option in the top menu listing of the page. Starting tomorrow, new
- [Quick Update](https://rhislop3.com/quick-update/) - Good afternoon! While you all haven't seen much on the face of the site, lots has been going on in the background. I/we are getting to the point of moving the site host for Reg's Blog. This will happen across the next couple of days. I believe the site will not suffer any article or
- [Friday Feature: Housekeeping](https://rhislop3.com/friday-feature-housekeeping/) - TGIF! Time for a bit of housekeeping. This site's first post was on March 27, 2009. Today, there are nearly 500 posts on the site, separate from other stuff like presentations, downloads, etc. Across the fifteen years I have worked on the site, posting, etc., I can't even begin to measure how many views or
- [FTC Bans Employment Non-Compete Provisions - Healthcare Implications Aplenty](https://rhislop3.com/ftc-bans-employment-non-compete-provisions-healthcare-implications-aplenty/) - On Tuesday, the Federal Trade Commission issued a final rule effectively, banning non-compete agreements, provisions, etc. for employees, including executives. The final rule contains separate provisions defining unfair methods of competition for the two subcategories of workers. Specifically, the final rule provides that, with respect to a worker other than a senior executive, it is
- [Regulation Monday: SNF Staffing Mandate and Medicaid Access Rule](https://rhislop3.com/regulation-monday-snf-staffing-mandate-and-medicaid-access-rule/) - Just announced this morning, CMS has finalized two hotly debated proposed rules into final rules. The final rules involve the SNF staffing mandate proposed last year and the Medicaid Access Rule, requiring 80% of payments for Medicaid HCBS programs go to compensation for direct care workers. The Medicaid Rule follows the original proposed rule while
- [Friday Feature: Back to the Future and Care Rounds](https://rhislop3.com/friday-feature-back-to-the-future-and-care-rounds/) - TGIF! A frequent reader sent me a note earlier in the week and asked if I would drop in more clinically oriented stuff from time to time. I asked for details, and she said stuff "that is germane to patient care and operational improvements - QA/QI stuff". So, today's post is by request, sort of.
- [Challenges Persist in Staffing for U.S. Life Plan Communities and Skilled Nursing Facilities](https://rhislop3.com/challenges-persist-in-staffing-for-u-s-life-plan-communities-and-skilled-nursing-facilities/) - Monday, Fitch Ratings dropped a Non-Rating Commentary about staffing challenges in Life Plan and SNF organizations. Per the release, "Though growing for some time, payrolls for U.S. life plan communities (LPCs) and skilled nursing facilities (SNFs) are still well off the pace needed to reach a full post-pandemic recovery." Bureau of Labor Statistics (BLS) data
- [Wednesday Feature: Budget Stuff...Cubed](https://rhislop3.com/wednesday-feature-budget-stuff-cubed/) - Happy Hump Day! Busy day so far but wanted to sneak this post in, wrapping up the last two days of posts on budget (federal, Medicare) stuff. This being the third day and post on budgets (and last for a while, I promise), the title fits - cubed. https://rhislop3.com/2024/04/15/monday-budget-day/ https://rhislop3.com/2024/04/16/medpac-report-to-congress-a-wrap-with-monday/ What follows is a different
- [MedPAC Report to Congress: A Wrap with Monday?](https://rhislop3.com/medpac-report-to-congress-a-wrap-with-monday/) - Yesterday I wrote a post on President Biden's healthcare budget. Today, I thought a quick visit back to March and MedPAC's Annual Report to Congress on payment and program adequacy would be a good "wrapper" - for now. Every year, MedPAC (the Medicare Payment Advisory Commission) reports to the Congress in March on the Medicare
- [Monday = Budget Day](https://rhislop3.com/monday-budget-day/) - As much as politics consumes the news, little on policy is included. Most days, the political stuff such as trials, Congressional hearings, back and forth tabloid (almost) stuff is front and center, missing is the "meat". Reminds me of the 80's Wendy's commercial titled, "Where's the beef?" https://www.youtube.com/watch?v=riH5EsGcmTw While I know that the national election,
- [Friday Feature: An End to Arbitration Clauses?](https://rhislop3.com/friday-feature-an-end-to-arbitration-clauses/) - TGIF! It's been a long week with the eclipse and lots of economic news plus all the stuff going on in the Middle East. My inbox is flooded so weekend reading will need to include a lot of parsing and pitching. On Tuesday in the Senate, a bill was introduced by Senators Blumenthal (CT) and
- [The Dark Side of the Economy](https://rhislop3.com/the-dark-side-of-the-economy/) - On Monday, a good portion of the U.S. saw all or portions of a total eclipse. If you were in the "zone of totality", you saw a heck of a show and witnessed the side-effects of day turning to dark and the weather turning noticeably colder. Cool stuff. Unfortunately, within the past week or so,
- [Recent HIPAA Right of Access Settlements Highlight Ongoing Enforcement Efforts](https://rhislop3.com/recent-hipaa-right-of-access-settlements-highlight-ongoing-enforcement-efforts/) - SNFs this one is for you! Yesterday's post on billing fraud was too. It almost feels as if this second week of April has a compliance theme while last week, the focus was on CMS Proposed Rules. Assuredly, Wednesday will bring some different news as March CPI data drops. This news came last week via
- [Medicare, DOJ, Fraud and the Eclipse?](https://rhislop3.com/medicare-doj-fraud-and-the-eclipse/) - Happy Eclipse Monday! The post title is meant as a bit of fun but there is a bit of relevancy as well. Billing fraud occurs via a process of hiding what actually has transpired (or should have) with the care of a patient. The most typical fraud is overbilling or charging the government for care
- [Reducing MDRO Prevalence in Healthcare Facilities: The Impact of Chlorhexidine Bathing and Nasal Decolonization on Hospitalizations](https://rhislop3.com/reducing-mdro-prevalence-in-healthcare-facilities-the-impact-of-chlorhexidine-bathing-and-nasal-decolonization-on-hospitalizations/) - I'm sure the first reaction to this title is, it's an April Fool's joke. This is not that. I know, I don't really write on any deep clinical topics, for various reasons. First, I'm not qualified clinically (I read to stay B.S. proof and to help my wife's work - clinical compliance). Second, my only
- [Wednesday Feature: Hospice Proposed Rule for 2025](https://rhislop3.com/wednesday-feature-hospice-proposed-rule-for-2025/) - Happy Hump Day! As I wrote in a post on Monday regarding CMS' Proposed Rule for SNFs, 'tis the season. This time of year, is when CMS drops proposed changes to reimbursement and other programmatic elements for all provider types, save Home Health which comes a little later (Home Health rate year is calendar year
- [Marketing to Fit the Times](https://rhislop3.com/marketing-to-fit-the-times/) - Over the years that I have been consulting, writing this blog, contributing to various publications, newsletters, podcasts, etc., I have tried to impress industry folks to stay connected to the current times in terms of marketing. By this I mean, don't lose sight of what is going on in the world around you, locally, nationally,
- [CMS Releases 2025 PPS Proposed Rule for SNFs](https://rhislop3.com/cms-releases-2025-pps-proposed-rule-for-snfs/) - It's that time of year again where CMS begins to drop various rule proposals for updates to provider groups under PPS. From Hospitals, to SNFs, to Home Health and Hospice, each industry segment will see a proposed series of rate and programmatic (rule) updates from CMS. This is normal and it occurs at about the
- [Wednesday Feature: How Old Am I?](https://rhislop3.com/wednesday-feature-how-old-am-i/) - Happy Hump Day! I needed a diversion day, away from the serious policy and econ stuff I usually follow and write about. All work and no play make Reg a dull boy. Folks that have followed this site for years or even newer followers, probably can tell that I write from a reference point. Experience
- [Sign of the Times: Petersen Health Care Files for Bankruptcy](https://rhislop3.com/sign-of-the-times-petersen-health-care-files-for-bankruptcy/) - Mid last week, Petersen Health Care, a Peoria, IL based nursing home operator filed for bankruptcy in Delaware. SC Healthcare Holdings LLC, which operates as Petersen Health Care, in federal court filings last Wednesday said it is seeking Chapter 11 bankruptcy protection because of ongoing financial problems partly due to an October ransomware attack and
- [Unprecedented Spike in Cancer Deaths: New Study Reveals Alarming Trend - Friday Feature](https://rhislop3.com/unprecedented-spike-in-cancer-deaths-new-study-reveals-alarming-trend-friday-feature/) - TGIF! I'm going to take the bulk of my day today away from work. I'm hoping to spend the afternoon with my wife, running errands and then catching dinner somewhere. Before I step away, an interesting article on increased cancer deaths between 2021 and 2022 caught my attention. In doing a bit of research, an
- [Tip-Toeing Through the (Healthcare)Econ Tulips](https://rhislop3.com/tip-toeing-through-the-healthcareecon-tulips/) - Bunches (pun intended) of economic data the past two weeks and as readers can tell from the title, I'm getting a little "punchy" with all the data. Anyone about my age should recall a celebrity known as Tiny Tim. His fame, short-lived as it should have been, including playing the Ukulele and signing in a
- [Wednesday Feature: Econ Rollercoaster](https://rhislop3.com/wednesday-feature-econ-rollercoaster/) - Happy Hump Day! This will drop before the Federal Reserve Open Market Committee announces its decision on interest rates today. Prediction: Rates will remain unchanged. The Fed will be a bit hawkish however, about rate policy reminding everyone that they are poised, if necessary, to hike rates to fight inflation. Thus, the title for today
- [Navigating Uncertainty: The Top Concern for CEOs in 2024](https://rhislop3.com/navigating-uncertainty-the-top-concern-for-ceos-in-2024/) - Heading into a rather busy week, I took inventory of stuff to write about this week, trying to organize in case of any other developing news this week, particularly coming out of the Federal Reserve meetings. Personally, though inflation remains a bit sticky and perhaps, even on a slight upward trend due to rising energy
- [15 Days to Slow the Spread: Remembered](https://rhislop3.com/15-days-to-slow-the-spread-remembered/) - On March 16, 2020, the Trump Administration released guidelines in response to the COVID-19 outbreak and the corresponding public health emergency. Four years later, much was learned, much was missed, much could have played-out different, and much remains to be reconciled. Today, four years later, we live with economic and societal ramifications from the public
- [Econ Tuesday: Houston, We Have a Problem](https://rhislop3.com/econ-tuesday-houston-we-have-a-problem/) - The February CPI report courtesy of the Bureau of Labor Statistics is out this morning and not only is inflation sticky, its ticking back up. I envisioned that the White House, upon seeing the report, said, at least silently, the famous Tom Hanks like from the movie Apollo 13 - "Houston, we have problem". The
- [Legislation Grab Bag](https://rhislop3.com/legislation-grab-bag/) - Within the normal news cycle, legislation often gets ignored, especially in this hyper volatile election cycle we have begun. I'm expecting very little in terms of reform or new legislation on important healthcare issues to come forward, and, so far, I'm right. With near gridlock due to small opposing majorities in both houses of Congress,
- [Friday Feature: You Will be Hated](https://rhislop3.com/friday-feature-you-will-be-hated/) - TGIF! I found this piece on LinkedIn and thought it was quite good and worthy of reposting in its entirety. I know what this is about, personally. I was an administrator, moreover, a senior living and healthcare CEO for many, many years. I ran large organizations primarily but the parallels within this story, don't change.
- [Penn and Teller and the Disappearing SNF](https://rhislop3.com/penn-and-teller-and-the-disappearing-snf/) - When I got married to my wife and business partner (the partner came after), part of our honeymoon was spent in Las Vegas. While there, we caught Penn and Teller's Vegas show and it was AWESOME! I love magic and in particular, the kind that is up close and personal. The trade term now seems
- [Wednesday Feature: A Peek into the Future](https://rhislop3.com/wednesday-feature-a-peek-into-the-future/) - Happy Hump Day! A favorite movie series of mine is Back to the Future, particularly parts 1 and 2. Made in the 80s, both are fun to watch in terms of their references to points in time, especially in part 2 where the "future" is 2015! Having lived through 2015, my memories don't quite compare
- [Friday Feature: Legal Battle Unfolds Over Nursing Home Negligence Amid Pandemic Era](https://rhislop3.com/friday-feature-legal-battle-unfolds-over-nursing-home-negligence-amid-pandemic-era/) - TGIF! Within a busy econ news week, a little litigation matter slipped into my news stream. These cases are fascinating as we continue to see the pandemic litigation trickle forward and the novelty of claims arising from the pandemic period/Public Health Emergency period beginning to define the litigation playing field. Readers/followers know by now that
- [The Hidden Factor Impacting Consumer Sentiment: Exploring Borrowing Costs](https://rhislop3.com/the-hidden-factor-impacting-consumer-sentiment-exploring-borrowing-costs/) - Today's post is rather short by comparison to others. It is an adjunct to yesterday's post regarding the credit market status for senior living and post-acute providers. Readers/followers that read the post will note that I included a fair amount of economic discussion, including some Federal Reserve minutes, to frame where I think rates and
- [Fast-Track Nursing Programs: Meeting America's Growing Need for Nurses?](https://rhislop3.com/fast-track-nursing-programs-meeting-americas-growing-need-for-nurses/) - Across this site, there are 400 plus posts spanning more than a decade. Sprinkled throughout, are posts on staffing and the need for labor, especially nurses. In other words, the U.S. health system, all provider segments, needs nurses and the pandemic exacerbated this need. The need is most critical at the bed side, direct care.
- [Wednesday Feature: Navigating the Evolving Landscape - Enhancing Ethics and Compliance Programs for Risk Mitigation](https://rhislop3.com/wednesday-feature-navigating-the-evolving-landscape-enhancing-ethics-and-compliance-programs-for-risk-mitigation/) - Happy Hump Day! Long title for what is going to be, a rather brief post. As followers and regular readers know, my firm (I am the co-founder and part owner) H2 Healthcare, LLC has a practice area uniquely concentrated on clinical compliance and complex litigation support. The practice area is headed by Diane Hislop, RN (yes,
- [Wednesday Feature: Ash Wednesday and the Start of Lent](https://rhislop3.com/wednesday-feature-ash-wednesday-and-the-start-of-lent/) - Happy Hump Day! Today is the start of the holiest of holiday seasons for Christians, the beginning of Lent leading up to Easter. Yesterday, known as Shrove Tuesday or Fat Tuesday for some, was the last day prior to the commencement of the six-week period of repentance and abstinence. Ash Wednesday is celebrated by Christians
- [Econ Tuesday: CPI Report Out, Heat Still On](https://rhislop3.com/econ-tuesday-cpi-report-out-heat-still-on/) - Welp, it's Fat Tuesday and the King Cake isn't any cheaper compared to last year. Nothing in today's January CPI report bears good news for senior living or healthcare providers as the headline inflation number was up .3% from December and 3.1% Year over Year. The Core (all items less food and energy) rose 3.9%. Soft
- [Unveiling the Allegations: Lawsuit Claims Advocate Aurora Health's Monopoly on Health System is Hiking Prices in Wisconsin](https://rhislop3.com/unveiling-the-allegations-lawsuit-claims-advocate-aurora-healths-monopoly-on-health-system-is-hiking-prices-in-wisconsin/) - Late last week, I ran across a number of news posts regarding a proposed class action lawsuit against the hospital/health system giant Advocate Aurora, alleging that the organization used its market mass to limit competition and in return, impose excessively high prices on commercial health plans and their insureds. The suit was filed in Wisconsin (where
- [Friday Feature: Litigation, Arbitration, and COVID](https://rhislop3.com/friday-feature-litigation-arbitration-and-covid/) - TGIF! I live and have an office in Illinois, though my part of the state differs dramatically from the Illinois most people recognize. I live and work in a small town (Galena) in an area known as the driftless region. The driftless region is "original" terra-firma, where the glaciers did not touch. This area is in the far northwest
- [Wednesday Feature: Healthcare Job Growth and the Economic Disconnect](https://rhislop3.com/wednesday-feature-healthcare-job-growth-and-the-economic-disconnect/) - Happy Hump Day! My apologies right off for such a head scratching title but this is where I am most days when I see economic reports like the recent jobs report (last week) from the Bureau of Labor and Statistics (report is here: January BLS Report 1 24 ) The news is good, maybe, kind of,
- [Occupancy? The Hidden Senior Living Market](https://rhislop3.com/occupancy-the-hidden-senior-living-market/) - While it is important to celebrate that senior living occupancies are up to pre-pandemic levels, it is also important to note that in most cases, the data quoted via NIC for example, is regionalized and nationalized. Likewise, the results (the occupancy levels) are still not capable of generating strong, positive margins. Occupancy levels in the 87% to
- [Rising Tide of Audits: Brace Yourself for Increased Scrutiny on Skilled Nursing Providers in 2024](https://rhislop3.com/rising-tide-of-audits-brace-yourself-for-increased-scrutiny-on-skilled-nursing-providers-in-2024/) - In 2023, regulators re-instituted audits of facilities for inappropriate diagnoses of schizophrenia (justification for anti-psychotic use), plus a five-claim audit of every nursing home. The purpose of the audit was to address a long-standing concern that inappropriate coding was driving higher Medicare reimbursement under PDPM, despite documentation in patient records, not substantiating the level of care
- [Friday Feature: Healthcare Economics Update](https://rhislop3.com/friday-feature-healthcare-economics-update/) - TGIF! A report I get and enjoy comes from Altarum (a non-profit consulting organization) looking at various economic data elements with regard to healthcare spending across a number of metrics (percent of GDP, time series growth, etc.). Granted, the report is a bit "wonky" but given what I do for a living, "wonky" is kind
- [Wednesday Feature -The Soaring Price of Care: How Retirement Costs are Reaching New Heights](https://rhislop3.com/wednesday-feature-the-soaring-price-of-care-how-retirement-costs-are-reaching-new-heights/) - Happy Hump Day! Today's post is shorter than normal as I have to attend a funeral on behalf of one of my partners (also a very close, close friend). His mom passed away recently, and the service is today. She was a wonderful woman, mom, wife, and grandmother and she will be missed by all who knew
- [Unraveling the Puzzle: Tackling Fragmented Healthcare for Better Patient Outcomes](https://rhislop3.com/unraveling-the-puzzle-tackling-fragmented-healthcare-for-better-patient-outcomes/) - An issue that I have been interested in for most of my career is coordinated care, especially in terms of older adults who utilize the most care resources and typically, have multiple providers (physicians in particular). Fragmented, uncoordinated care is the primary driver of over-treatment or inefficient treatment. The outcomes of over-treatment include polypharmacy, test
- [Record Bankruptcies in Health Care in 2023](https://rhislop3.com/record-bankruptcies-in-health-care-in-2023/) - As the economy continued to struggle through a high inflationary cycle with restrictive Federal Reserve policy in-place to curb inflation, providers struggled to stay afloat in the turbulent economic waters. Significant financial headwinds in 2023 have only modestly abated at the start of 2024. Labor supply issues (shortages) of direct care staff (other disciplines as well)
- [Wednesday Feature: Neglected, Uninspected - Senate Aging Committee Report on SNF Surveys](https://rhislop3.com/wednesday-feature-neglected-uninspected-senate-aging-committee-report-on-snf-surveys/) - Happy Hump Day! Yesterday I wrote about the OIG's (Department of Health and Human Services) report and focus on CMS' oversight of state survey agencies. The impetus behind this focus no doubt comes from the U.S. Senate Special Committee on Aging's investigation into nursing home survey activities at the state level. The report is available
- [OIG: CMS Should Take Action Against States with Poor SNF Survey Performance](https://rhislop3.com/oig-cms-should-take-action-against-states-with-poor-snf-survey-performance/) - Last week, the U.S. Department of Health and Human Services Office of the Inspector General (OIG), issued a report regarding the performance of contracted state agencies with respect to nursing home (SNF) compliance surveys. CMS contracts with state agencies, typically state departments of health or divisions thereto, to perform compliance/regulatory activities (surveys) in nursing homes. The report
- [Fitch 2024 Oulook: Life Plan (CCRC) Communities, Non-Profit Hospitals - Deteriorating](https://rhislop3.com/fitch-2024-oulook-life-plan-ccrc-communities-non-profit-hospitals-deteriorating/) - The Fitch Ratings Public Finance outlook dropped earlier this week and not surprising, their outlook for Life Plan Communities and Non-Profit Hospitals/Health Systems remains negative or in their terms, "deteriorating". Their forecast is for deteriorating credit conditions in these two sectors due primarily to labor and cost pressures (insufficient supply of labor at higher comp levels
- [Wednesday Feature: Snow Day, Hump Day](https://rhislop3.com/wednesday-feature-snow-day-hump-day/) - Winter officially arrived yesterday and overnight, dumping anywhere from six inches to a foot plus of snow in my region. The snow is affectionately known as "heart attack" snow - the wet, heavy kind. It is, however, extremely pretty as it clings to the trees. Today's post is just for fun as I've been too busy
- [Final Independent Contractor Rule: Implications for Health Care](https://rhislop3.com/final-independent-contractor-rule-implications-for-health-care/) - This morning, the Department of Labor issued a final rule interpreting who is and who is not, an independent contractor v. an employee. Contract work in health care has boomed since the pandemic, though even pre-pandemic, the use of contractors (physicians, nurses, therapists, etc.) was on the increase. The final rule is available here: 2024-00067 The
- [SNF Closure Risks Increasing](https://rhislop3.com/snf-closure-risks-increasing/) - Two articles in my email caught my attention to start the week. Both have to do with SNF closure risks, one regarding rural facilities and the other regarding staffing challenges. Interesting enough, both cross the same issues for closure, approached however, somewhat differently. I've written about this subject for years now yet, attention has only become acute
- [Friday Feature: The Economic Impact in Aging Countries](https://rhislop3.com/__trashed/) - TGIF! The U.S. is aging. Its median age is 37.7, just behind China's median age of 37.9. Comparatively, the U.S. would be considered young in relationship to Japan where the median age is 48.4. While it is true that the Japanese have a longer life expectancy than the average American (84.6 years vs. 77.29 years),
- [COVID Assisted Living Claim in Virginia - Potentially Precedential](https://rhislop3.com/covid-assisted-living-claim-in-virginia-potentially-precedential/) - My work has me very attuned to litigation trends and in particular, COVID litigation. We are just beginning to see COVID litigation coming to a head with some interesting decisions. Within my firm (H2 Healthcare, LLC), is a practice focus headed by my wife. It involves clinical compliance and complex litigation support. She is considered one of, if
- [Wednesday Feature: Outlook for 2024](https://rhislop3.com/wednesday-feature-outlook-for-2024/) - Happy Hump Day! I hope all readers, followers, and visitors had a great Christmas Holiday. This post will likely wrap-up 2023 for me as tomorrow, I begin a bit of travel to see some long-time friends and celebrate the New Year. I am not much for resolutions into the new year as I try to
- [The Impact of Baby Boomers on Senior Living/Senior Healthcare](https://rhislop3.com/the-impact-of-baby-boomers-on-senior-living-senior-healthcare/) - The oldest boomers are about to turn 80 in 2026. This age point is typically the trigger point for advancing needs in secure living environments, services increase (ADL and IADL support), and increasing healthcare consumption. The baby boom generation is defined as folks born between 1946 and 1964. The "boom" reference is the rapid number of children
- [Friday Feature: Merry Christmas](https://rhislop3.com/friday-feature-merry-christmas/) - TGIF and Merry Christmas! The year has flown and now, it's time to get away from a keyboard and from work and focus on what really matters - faith and family. Soon, I will reflect again on the most wonderful story of all, the birth of Jesus. The season of Christmas does not exist without
- [Genesis and COVID Litigation - Interesting Update](https://rhislop3.com/genesis-and-covid-litigation-interesting-update/) - Genesis is one of the country's largest SNF and assisted living providers so naturally, it saw its share of COVID cases throughout the pandemic. Like other similar providers across the same industry, cases involving COVID infections are just now hitting the courts. Back in October, I wrote about the advancement of litigation involving COVID. There
- [Wednesday Feature: Santa Claus is Coming to Town](https://rhislop3.com/wednesday-feature-santa-claus-is-coming-to-town/) - Happy Hump Day! I'm getting close to putting a bow on this site and wrapping it up for the Holidays, or at least, until after Christmas. There may be one more health policy post to get out before a brief hiatus. In the meantime, the festive part of the season is slowly ingulfing me, so today's
- [Friday Feature: Hopeful](https://rhislop3.com/friday-feature-hopeful/) - TGIF! It is the Advent season for Christians and the end (another day) of Hanukkah for Jews. Both seasons to me, bring joy and hope. I have good Jewish friends, so I get a bit of a celebratory joy from them, especially since they reciprocally enjoy Christmas celebrations. As readers know, I follow health care and health
- [Humana, United Health: Class Action Suits over AI use in Coverage Determination](https://rhislop3.com/humana-united-health-class-action-suits-over-ai-use-in-coverage-determination/) - It was only a matter of time before litigation came forward regarding the use of Artificial Intelligence (AI) in primarily, Medicare Advantage plans, where coverage denials/determinations are at issue. This week, a class action suit dropped in the U.S. Circuit Court of Western Kentucky against Humana. A link to the suit is here: https://www.scribd.com/document/692182281/Humana-AI-NaviHealth-MA-lawsuit In
- [Wednesday Feature: SNF Ownership Transparency](https://rhislop3.com/wednesday-feature-snf-ownership-transparency/) - Happy Hump Day! Only 12 more shopping days until Christmas! In mid-November, CMS issued a final rule titled: "Medicare and Medicaid Programs; Disclosures of Ownership and Additional Disclosable Parties Information for Skilled Nursing Facilities and Nursing Facilities; Medicare Providers' and Suppliers' Disclosure of Private Equity Companies and Real Estate Investment Trusts". The final rule is
- [MedPAC Recommendations: Home Health, Hospice, Inpatient Rehab Facilities](https://rhislop3.com/medpac-recommendations-home-health-hospice-inpatient-rehab-facilities/) - Yesterday I wrote about MedPAC's rate recommendations for SNFs for FY 2025. Recall, MedPAC makes these recommendations annually, assuming the full commission votes (in January 2024) for the recommendations as released by draft. The final recommendations go to Congress. Yesterday's post was the "draft" position for SNFs. Today, I'm including summaries for Home Health, Hospice,
- [MedPAC Recommends 3% Rate Cut for SNFs - 2025](https://rhislop3.com/medpac-recommends-3-rate-cut-for-snfs-2025/) - The Medicare Payment Advisory Commission is (likely) recommending to Congress a series of post-acute rate reductions (Medicare, Fee-for-Service) for federal fiscal year 2025 (beginning October 1, 2024, for most programs, January 1, 2025, for Home Health Agencies). Specifically, the MedPAC recommendations are as follows. Reduce the 2025 payment rate for home health agencies by 7%.
- [Friday Feature: Affordability of Senior Living and Services](https://rhislop3.com/friday-feature-affordability-of-senior-living-and-services/) - TGIF and Happy Hanukkah (to my Jewish colleagues and friends)! A major concern as the demographic in the U.S. ages is senior housing and services affordability. The expanding cohort of seniors in terms of real purchasing power, is not as financially fit as prior generations. The Baby Boomers for example, while well paid in their
- [Medicaid: HCBS and Eligibility Updates](https://rhislop3.com/medicaid-hcbs-and-eligibility-updates/) - I follow Medicaid but don't often get many inquiries around Medicaid policy or requests for articles in this subject area. Medicaid, however, is very important for providers, especially post-acute and senior living, as it is typically, a significant if not majority payer. During COVID and the public health emergency, Medicaid policy and CMS enacted requirements
- [Wednesday Feature: Recession Ahead?](https://rhislop3.com/wednesday-feature-recession-ahead/) - Happy Hump Day! Advent has begun and soon, Chanukah will kick-off. 'Tis the season or seasons. I will no doubt say this (or write it) many times over, but it always bears repeating, Happy Holidays to all! Yesterday, I wrote a post about Fitch Rating's and their outlook for CCRCs/Life Plan communities for 2024. Fitch maintained
- [Twofer Tuesday: Life Plan/CCRCs, Fitch Outlook (2024) and Rate Concession Report](https://rhislop3.com/twofer-tuesday-life-plan-ccrcs-fitch-outlook-2024-and-rate-concession-report/) - Long title for a Tuesday. Two reports dropped within the last couple of days and into my email regarding CCRCs/ Life Plan communities and some interesting trends/outlooks. Yesterday (Dec 4), Fitch issued its 2024 outlook for Life Plan/CCRCs, reaffirming its 2023 outlook as "deteriorating". The primary reason for the gloomy outlook is present and projected,
- [Friday Feature: Senior Living Litigation Watch: Risks at CCRCs/Independent Living](https://rhislop3.com/friday-feature-senior-living-litigation-watch-risks-at-ccrcs-independent-living/) - Among the many topical areas I watch in health care, I pay particular attention to liability and litigation. As frequent readers/followers know, my firm, H2 Healthcare, LLC, focuses a practice area on clinical compliance and litigation support. My wife and the firm's Senior Partner is one of the foremost experts (nationally) in litigation support and
- [Wednesday Feature: CEO Burnout is Real](https://rhislop3.com/wednesday-feature-ceo-burnout-is-real/) - Happy Hump Day! As readers would expect, I spend a ton (ok, maybe not a ton but a lot) of time reading and researching for client purposes and for this site. Over the years, I have found developing subject level knowledge has kept me sane and given me a deep perspective on health care and
- [Value-Based Care: What it is and How it Can Work for Post-Acute Providers](https://rhislop3.com/value-based-care-what-it-is-and-how-it-can-work-for-post-acute-providers/) - I get asked about value-based care a lot. It is a buzzword or term these days, somewhat driven by the rise in Medicare Advantage enrollment. Frankly, it is a bit of a catch-all concept that has its origins in Medicare and various demonstration projects (e.g., bundled payments) and the implementation of quality measures to "improve
- [OIG Issues Report on SNF Emergency Preparedness](https://rhislop3.com/oig-issues-report-on-snf-emergency-preparedness/) - Since the COVID pandemic, regulatory officials have escalated the review, via various audits, of SNF emergency preparedness. COVID highlighted the sporadic and often, non-existent preparations for disasters (natural and other) and disease outbreaks (pandemic or other) that existed with the SNF industry. In reality, the issues have been present for years but only regionally, highlighted
- [Wednesday Feature: Happy Thanksgiving!](https://rhislop3.com/wednesday-feature-happy-thanksgiving/) - This post will be a wrap for me for the week. No more work as friends and family will soon come calling and my multiple tasks of cooking the Thanksgiving dinner will take precedent. One thing I will be thankful for, among soooo many blessings, is this little bit of work I do on this
- [Hospice Special Focus, IDR, and Quality Reporting Program - 2024](https://rhislop3.com/hospice-special-focus-idr-and-quality-reporting-program-2024/) - Somewhat buried within the Home Health Final Rule (PPS) was an update on a CMS initiative to identify hospice agencies requiring additional regulatory oversight for poor care performance (poor quality, unsafe care practices). Back in 2021, CMS began the Special Focus initiative and in the 2024 Hospice Final Rule, CMS indicated that the recommendations for
- [Compliance Update: Fraud and Abuse](https://rhislop3.com/compliance-update-fraud-and-abuse/) - A complex area for providers, especially with respect to their compliance programs, are the concepts of fraud and abuse. Central to current requirements for compliance programs, all post-acute providers are REQUIRED to have compliance programs that, Include policies and procedures to define, test for, and mitigate any issues pertaining to fraud and abuse. In this
- [Friday Feature: Senior Living Credit/Borrowing Still, Very Soft](https://rhislop3.com/friday-feature-senior-living-credit-borrowing-still-very-soft/) - TGIF! This week has been very busy with lots of data and lots of economic news. We got a new report from the BLS on inflation. We got earnings reports from Home Depot, Target, and yesterday, Wal Mart indicating what we saw from the Conference Board - consumers are slowing their spending. I called the
- [Wednesday Feature: CPI, Economy, 40 Days to Christmas](https://rhislop3.com/wednesday-feature-cpi-economy-40-days-to-christmas/) - OK, the title is kind of funky, but these concepts do connect. Yesterday, the Bureau of Labor Statistics released the Consumer Price Index (inflation report) for October, 2023. Good news? Maybe. A mixed bag? Definitely. Headlines win the day, and politically spun, it's fascinating to see which numbers resonate. The full report/release is here: cpi
- [Hospice Payment Basics/MedPAC](https://rhislop3.com/hospice-payment-basics-medpac/) - Even after all of the years that I have been in health care and particularly, post-acute care, I still field a good number of questions regarding Hospice, the benefit under Medicare, how payments work, and what the generalized payment amounts are. Having started a few hospices in my career, I can attest that done right,
- [Friday Feature: Veterans Day](https://rhislop3.com/friday-feature-veterans-day/) - Tomorrow is the official Veterans Day holiday. Today is the observance day of Veterans Day. Veterans Day is a federal holiday, created to honor the service of men and women in any branch of the U.S. armed services that were discharged honorably. While current active-duty individuals are often part of Veterans Day observances (their holiday
- [National Signing Day!](https://rhislop3.com/national-signing-day/) - Today is national signing day for 2024 athletes and my firm's partner, Theracore Management Group has a celebration. Of the two Theracore original principals, the co-owner and COO, Dean Freeland, had his daughter announce her commitment to Illinois State University. Saveea Freeland (Dean's daughter) is a multi-sport phenom and a top of her class student.
- [Wednesday Feature: A Bit of Economic Nostalgia](https://rhislop3.com/wednesday-feature-a-bit-of-economic-nostalgia/) - Happy Hump Day! I was going back through some historic stuff and I landed in 2010. The year 2010 was, after further review, eerily similar to right now, economically speaking. Sadly, not much has changed in terms of health policy and the economic state of healthcare. In 2010, the economy was choppy, recovering or trying
- [3rd Quarter Senior Housing Update](https://rhislop3.com/3rd-quarter-senior-housing-update/) - Senior Housing has had a long, slow grind toward recovery, post-pandemic. Fitch classified the Life Plan component as "deteriorating". Among the many challenges the industry sectors (Independent, Assisted, Life Plan) faced, access to capital and access and maintenance of dependable and qualified labor are the two most challenging. COVID shaved occupancies rather substantially. Pre-pandemic, as
- [Friday Feature: Senior Living Investment Outlook](https://rhislop3.com/friday-feature-senior-living-investment-outlook/) - TGIF! On a calendar year basis, we are into the home stretch for 2023. It's generally about now that I start looking at how 2024 is shaping up. What trends are there to watch? What do markets look like now, socially and economically? What does policy and politics tell us about the year to come?
- [SNF Staffing, Mandates, and More](https://rhislop3.com/snf-staffing-mandates-and-more/) - Seema Verma, former CMS head, spoke out yesterday regarding the proposed staffing mandate (hours and type of staff, per resident per day) proposed rule, indicating her opinion that the approach was flawed. A recap article on her comments is here: https://www.mcknights.com/news/former-cms-chief-verma-regulators-over-their-skis-with-staffing-mandate/?utm_source=newsletter&utm_medium=email&utm_campaign=NWLTR_MLT_DAILYUPDATE_110223&hmEmail=IjP1GPaY%2BJ2uvsLxTJ79bVeRWY7ycbnr&sha256email=aa4cb7c695037c31a216b9562788596b6fcd012145d566f31440b6fcd139c8a9 Regular readers know that I have covered various topics on healthcare staffing, particularly as
- [Wednesday Feature: The Power of Positive Thinking](https://rhislop3.com/wednesday-feature-the-power-of-positive-thinking/) - Happy Hump Day and Happy All Saints Day or All Hallows Day! For many in Latin American countries, this day is far bigger than Halloween. It is a day to celebrate Christian martyrs and saints known and unknown, celebrating the connection between the living and the deceased. In Catholicism, it is a day of reverence
- [MedPAC and Medicare Advantage](https://rhislop3.com/medpac-and-medicare-advantage/) - In yesterday's post, Mish-Mash Monday, in the section about the House Budget Committee's Health Care Task Force, I offered some commentary regarding MedPAC (Medicare Payment Advisory Commission) and Medicare Advantage plans. I also included a letter from the senior living trade association LeadingAge to the Congressional task force that references MedPAC's concerns regarding Medicare Advantage
- [Mish-Mash Monday](https://rhislop3.com/mish-mash-monday/) - A new week and lots of data/info. coming on a variety of fronts. Today's post is less about one thing and more about a few things, a bit of smorgasbord to start the week. State by State SNF Data/CLA: Back at the start of the month, I wrote a post on the state of the SNF
- [Boomers and Senior Living: What to Expect](https://rhislop3.com/boomers-and-senior-living-what-to-expect/) - There is a constant discussion within the senior housing/senior living industry about the impact Baby Boomers will have on the industry. Their numbers (boomers) are huge (hence the name, "boomers"). The Baby Boom generation name is reflective of the post-WWII period of 1946 to 1964. During this period, families grew rapidly having two or more
- [Wednesday Feature: Another, Different Pandemic](https://rhislop3.com/wednesday-feature-another-different-pandemic/) - Happy Hump Day! The purpose of these Wednesday detours from the usual health policy, economics, senior living/senior housing/post-acute care stuff is to help readers and followers either add a touch of levity to their day or (to) cause them to think a bit differently about the world. Consider Wednesday Features as a deviation from the
- [Sr. Living M&A Update - Third Quarter](https://rhislop3.com/sr-living-ma-update-third-quarter/) - This topic fits a line from the old police serials of my younger days. These are the favorites I watched religiously like Adam-12, the Rookies, The FBI, etc. The line, generally at a crime scene: Move on folks, nothing to see here. That line fits today's topic. The mid-year report illustrated softness in activity principally
- [Friday Feature: A Day Off](https://rhislop3.com/friday-feature-a-day-off/) - I have the pleasure of living in one of the more beautiful spots of the country. I am biased but I also, am not alone in this opinion. Galena, IL is home and where my/our office is. Conde Nast ranks it as one the friendliest cities in America and Forbes called it one of the
- [Twofer Thursday: Staffing Litigation and a Bit More on Medicare Advantage Plans](https://rhislop3.com/twofer-thursday-staffing-litigation-and-a-bit-more-on-medicare-advantage-plans/) - Today's post is a bit of a hybrid. I'm trying to keep up with a bunch of things ranging from policy to economics (Jerome Powell speech today) to some work stuff so I'm combining two things today that probably, deserve a bit more dissection, but this will do for now. Plus, I'm hopeful that tomorrow
- [Wednesday Feature: The Meaning of Life](https://rhislop3.com/wednesday-feature-the-meaning-of-life/) - Happy Hump Day! The last two weeks have definitely been interesting (and troubling), geopolitically speaking. It seems like too many areas of the world are in turmoil, either in war (Israel, Ukraine) or on the brink thereof (Taiwan). I have many Jewish friends, some very close to me. I feel for them, especially given how
- [Medicare Advantage - Status Update](https://rhislop3.com/medicare-advantage-status-update/) - Medicare Advantage plans or Medicare Part C and D plans continue to grow in popularity. I've written a number of posts on various Medicare Advantage topics, of late, coverage issues and denials, particularly for post-acute care stays. A recent post on that topic is here: https://wp.me/ptUlY-wI Medicare Advantage plans (Part C plans) include Parts A,
- [Sr. Living, Litigation and COVID Implications](https://rhislop3.com/sr-living-litigation-and-covid-implications/) - On Friday, I wrote about the explosion of COVID litigation in health care and senior living, especially that which is challenging federal immunity under the PREP Act and cases challenging insurance coverage for business interruption coverage resultant from COVID remediation policies (business closure, school closures, vaccine requirements, etc.). Today's post is a bit more focused
- [COVID-19 Response and Pandemic Preparedness: Redux](https://rhislop3.com/covid-19-response-and-pandemic-preparedness-redux/) - As COVID-19 has moved to an endemic phase (constant presence, not spreading out of control or taxing health care resources), I've started to look back at what transpired since early-2020 and what was learned, known, and now, embedded (perhaps) in our culture and our health care industry. Suffice to say, the review is somewhat mind
- [Wednesday Feature: Mental Health](https://rhislop3.com/wednesday-feature-mental-health/) - Yesterday was National Mental Health Day. It was also World Mental Health Day. The purpose of the day is to raise awareness of mental health issues and to mobilize professionals and communities to become more engaged in supporting mental health care. A few months back, I lost a very close, long-term friend to a mental
- [Value-Based Care: Why it Matters, or Should, for Post-Acute Providers](https://rhislop3.com/value-based-care-why-it-matters-or-should-for-post-acute-providers/) - Value-Based Care is kind of a vogue term, one that I encounter quite often. I also have used it when speaking or writing and know most people have no idea what it means or how it can be developed and/or applied. Value-based care is not a new concept. Medicare tried a foray into it back
- [How Much is Enough? Deficits, Debt, and a Look Into the Future](https://rhislop3.com/how-much-is-enough-deficits-debt-and-a-look-into-the-future/) - Lately, I've gotten quite a bit of 70s (1970s) deja vu. Yes, I'm old enough to vividly remember the 70s as I crossed the decade as a teenager, graduating high school and almost, college. If one has my memories, the 70s were pretty turbulent times, analogous to now. In 1973, Israel and the Arab (Egypt
- [Friday Feature: Sr. Living Occupancy Update + (plus)](https://rhislop3.com/friday-feature-sr-living-occupancy-update-plus/) - Yesterday we got a good look at the status of the SNF industry via a data report from CLA. Today, as the week ends, we can look at the broad industry as a whole and where occupancies are trending. NIC (National Investment Center) released its occupancy snapshot for senior living for Quarter 3. That summary
- [SNF Industry Update](https://rhislop3.com/snf-industry-update/) - Every year, the accounting firm of Clifton Larson Allen (CLA) produces an industry trends report based on accumulated cost report data. The report provides a good snapshot of the nursing home industry, nationwide, with insights on regions and states. The report is available here: 38th-snf-cost-comparison-and-industry-trends-report As I've written on numerous posts on this site, the
- [Wednesday Feature: Insanity](https://rhislop3.com/wednesday-feature-insanity/) - Happy Hump Day! Every once in a while, I feel the need to rant, if just a bit. Personally, it's like an exorcism of pent-up frustration. Since this blog is mine and I am the author, editor, chief cook, and bottlewasher, I get a certain license to write stuff that I feel is important. I
- [Twofer Tuesday: Jimmo and Staffing Mandates](https://rhislop3.com/twofer-tuesday-jimmo-and-staffing-mandates/) - Happy Hump Day eve! There is so much going on right now with the economy, government shutdown (whew, avoided that one for a bit) dynamics, election news, and health policy that it is becoming difficult to parse topics into stuff of value. Hopefully, a couple of quick updates will make room for more insightful analysis
- [AZ Pandemic Related Case - Watchlist Important](https://rhislop3.com/az-pandemic-related-case-watchlist-important/) - My firm (shared with my co-founder) H2 Healthcare, LLC does a lot of legal work, primarily forensic and litigation support. My wife (and partner), Diane Hislop, RN, is likely the foremost (or certainly, top few) clinical compliance experts in the country in terms of senior living and post-acute care. This means, as a group, we
- [Friday (and Weekend) Feature: A Bit Tardy](https://rhislop3.com/friday-and-weekend-feature-a-bit-tardy/) - Busy week and so, I got a tad behind. Lots of news to run through this weekend from health policy stuff (new MDS next week), to updated numbers on SNF staffing mandates, some new info. on the Jimmo case (ten years ago) and Medicare denials, and some economic data from yesterday and today (mixed bag
- [Wednesday Feature: Autumn](https://rhislop3.com/wednesday-feature-autumn/) - Well, this Saturday past, September 23, ushered in fall with the arrival of the Autumnal Equinox. On this day, the rotation of the Sun shifted to its midpoint in the journey, on the way to the southern hemisphere. In other words, the sun's highest point now is at the equator, and the result for us
- [Quality and Quantity of Life for Seniors, in Senior Housing](https://rhislop3.com/quality-and-quantity-of-life-for-seniors-in-senior-housing/) - Since my first years in senior housing and health care, and my work way back when with Alwyn Powell (AV Powell, AV Powell and Associates), I have been fascinated by the aging journey in care settings - lengths of stay, health care utilization, quality of life and quantity of life. I've supported numerous research studies
- [Friday Feature: Where Inflation Came from and Why](https://rhislop3.com/friday-feature-where-inflation-came-from-and-why/) - The Federal Reserve hasn't always conducted FOMC meetings (Federal Open Market Committee). It started meeting in late 1973 or early 1974. The purpose of the meeting was to address inflation primarily, in the economy; ways to control it, ways to stabilize monetary policy, ways to create price stability. In the mid 1970s, the Fed began
- [Fitch, Life Plan (CCRCs) and the Economy: Could Get Uglier](https://rhislop3.com/fitch-life-plan-ccrcs-and-the-economy-could-get-uglier/) - On Monday, Fitch (investment rating agency) dropped a non-rating commentary as an alert that should the economy hit a recession (I would argue not "should" but "when"), that Life Plan communities will encounter additional financial pressure. Recall that in December 2022, Fitch issued its outlook on the Life Plan/CCRC market, qualifying it as "deteriorating." Per
- [Wednesday Feature: A Great Leadership Lesson](https://rhislop3.com/wednesday-feature-a-great-leadership-lesson/) - Happy Hump Day! The number one reason for staff turnover is NOT money, its bad bosses or moreover, the things that bad bosses do. I have had staff follow me from engagement to engagement (job to job) and still, have staff that would meet and work with me, anywhere (well, almost) anytime. Why? It isn't
- [Senior Housing Occupancy Update](https://rhislop3.com/senior-housing-occupancy-update/) - During the pandemic, senior housing (all forms) saw a drop, some precipitous like SNFs, in occupancy. As the pandemic has now waned, the recovery continues. This is good news for the sector, but occupancy is not the only factor impacting recovery. According to the National Investment Center (NIC), occupancy in the sector varies between market
- [Wednesday Feature: It's the Economy, Stupid](https://rhislop3.com/wednesday-feature-its-the-economy-stupid/) - The title may jog memories for some readers. During the 1992 election cycle, advisor to then candidate Bill Clinton, James Carville, (running against George H.W. Bush) used the phrase for campaign workers as a charge to focus on. He wanted people to pay attention to the economic issues (inflation) affecting how people were feeling about
- [Memory Care: 9/11](https://rhislop3.com/memory-care-9-11/) - Twenty-two years ago, 9/11/2001, my day began as most did back then. I got up, read the paper, turned on NBC local news as it would move then, to the Today Show. I ate my usual breakfast (something light) and drank a cup or two of coffee. My wife had left for Madison (WI) where
- [Five Quality and Compliance Tips](https://rhislop3.com/five-quality-and-compliance-tips/) - A major concentration within my firm, H2 Healthcare, is compliance work. My wife heads this section of the practice, and she is widely known as one of (if not THE) the foremost post-acute/senior living experts on clinical quality, compliance, and risk mitigation/risk management. Her book on reducing survey risk for SNFs is still available on
- [Wednesday Feature: Fall is Coming!](https://rhislop3.com/wednesday-feature-fall-is-coming/) - After a few days of mid-summer weather (90s, humid), my calendar says fall is right around the corner, even if the weather doesn't. I love fall. It's my favorite time of year. Living in the upper-Midwest, fall can be just spectacular. Soon, the days will be warm and the evenings chilly. Woodfire smoke (not the
- [SNF Performance Update - Occupancy, etc.](https://rhislop3.com/snf-performance-update-occupancy-etc/) - No other segment of senior living/senior care got rocked as much by the pandemic as skilled nursing. Frankly, the industry had challenges from labor shortages and lagging reimbursement entering the pandemic (2020). The pandemic didn't just accentuate these issues, it blew them up in terms of magnitude (impact) while adding supply chain issues, inflation, and
- [Friday Feature: Buffet on Management and Boards of Directors](https://rhislop3.com/friday-feature-buffet-on-management-and-boards-of-directors/) - I ran across this yesterday in a publication I get called Becker's Hospital Review. I recall seeing much of the content before and really liking it. It is from famed investor and Chair of Berkshire Hathaway, Warren Buffet. It is content from his letters to Berkshire Hathaway shareholders from years back, 1977 to be exact.
- [Wednesday Feature: CMS SNF Staffing Mandate Stalled?  The Abt Report on Feasibility...](https://rhislop3.com/wednesday-feature-cms-snf-staffing-mandate-stalled-the-abt-report-on-feasibility/) - Happy Hump Day! Another Wednesday with news too heavy to ignore. I'll try to return to some levity and light in future Wednesday features. For a number of years, CMS has been playing with developing a staffing level mandate. The first CMS study from 20 years ago recommended a 4.1 hours per day benchmark. Recently,
- [SNF Final Rule 2024 - Update](https://rhislop3.com/snf-final-rule-2024-update/) - Back a few weeks ago I did a post summarizing the 2024 Final PPS Rule for Skilled Nursing Facilities. Recall, these rules come out yearly, updating payment rates and other provisions impacting payment and some, impacting policy. Typically, the initial or proposed rule starts in spring and then after comments, etc., becomes final during the
- [Politics and Health Policy](https://rhislop3.com/politics-and-health-policy/) - Last week, the 2024 Presidential campaign season kicked into full swing with the first candidate debate. Arguably, momentum has been building ahead of the debate, especially in Iowa, during the State Fair, where candidates roamed, gave speeches, and pressed the flesh. I was there one day and enjoyed seeing Tim Scott and few other notables,
- [Friday Feature: CMS Updates RAI Manual for SNFs](https://rhislop3.com/friday-feature-cms-updates-rai-manual-for-snfs/) - As foretold in the SNF PPS Final Rule, CMS was going to fine tune the MDS/RAI manual prior to October 1 when the new 2024 Fiscal Year starts. Generally, data such as this update comes much closer, sometimes even after the October 1 implementation date. Providers get a break for a change. Initial proposed changes
- [SNF Claims Audits so Far - Messy](https://rhislop3.com/snf-claims-audits-so-far-messy/) - Back in early June, I wrote a post on how Medicare/CMS was intending to audit 5 claims from every participating SNF in the country. The audits would be staggered and conducted by MACs (Medicare Audit Contractors). That post is available here: https://wp.me/ptUlY-AR As we are now three months into the audit process, details are emerging
- [Wednesday Feature: CMS Targeting 400 Hospices for Administrative Action](https://rhislop3.com/wednesday-feature-cms-targeting-400-hospices-for-administrative-action/) - Usually I try to add some "light and levity" to my Wednesday features as the content on this site is pretty heavy health policy and economics, regulatory in nature, etc. In my work, my usual Wednesday messages internally are "fun" - a bit of Hump Day humor or whimsy. By title of this post, readers
- [High Acuity Assisted Living and Home Health Becoming a Trend?](https://rhislop3.com/high-acuity-assisted-living-and-home-health-becoming-a-trend/) - With a push to find increasing value in care delivery on the part of payers, providers in assisted living and home health are seeking to carve out a niche in what can best be described as "hospital or acute care" alternative locations. The most forward trend is occurring in home health, known as hospital-at-home care.
- [Trouble for Rural Hospitals](https://rhislop3.com/trouble-for-rural-hospitals/) - I spend a lot of time in rural America, primarily in the upper-Midwest (Iowa, Wisconsin, Illinois, etc.). With the pandemic, the struggling economy, high inflation, high energy costs, labor supply challenges, and rising interest rates, rural health care is struggling like never before. A story on the Fox Business website captures the plight of rural
- [Friday Feature: SNFs and Hospices](https://rhislop3.com/friday-feature-snfs-and-hospices/) - Typically, I get the Friday Feature posts out early enough on a Friday for folk to read before a longer weekend or leaving the office early. Working today with my wife on an SNF/Hospice litigation matter got me behind but the same did form today's Feature. My wife's practice and our firm are seeing more
- [The Status of RNs in Health Care](https://rhislop3.com/the-status-of-rns-in-health-care/) - Nurses, particularly RNs, and their role and work in health care is a subject of deep interest to me. My wife is a nurse, our daughter is a nurse, my mom was a nurse, and so was my aunt. One could say nursing and nurses (RNs in particular) "run in the family". I have written
- [News and Upcoming Quality Program](https://rhislop3.com/news-and-upcoming-quality-program/) - Yesterday, I wrote a post regarding health systems and providers looking at finding efficiencies and, in some cases, cutting staff - particularly at the administrative and executive levels. Providers are being tasked with making do with less as the economic headwinds remain stiff, even gale force in some cases. Part of the challenge for providers
- [Cuts and Layoffs are Happening](https://rhislop3.com/cuts-and-layoffs-are-happening/) - As the economy remains "challenging" and providers are finding rising capital costs and rising staffing costs, survival mode is where many are operating. For any hospital, SNF, Home Health Agency, or Hospice, labor (wages and benefits) is typically about 60% of the expense budget. With direct care staff in short supply in nearly every market
- [Friday Feature: The Benefit of R&R](https://rhislop3.com/friday-feature-the-benefit-of-rr/) - I've been rather busy lately and my wife's side of the practice (compliance, litigation), very much so. Suffice to say, as the two prime partners and owners of H2 healthcare, we work collaboratively and support each other. In other words, her "busy" is mine too and vice-versa. So today, I'm setting aside for catch-up and
- [Tapas Thursday: Small Health Policy News Bites](https://rhislop3.com/tapas-thursday-small-health-policy-news-bites/) - I like tapas from time to time, especially for a happy hour gathering. Thursday seems to always be a good day to have little bites of something prior to a big weekend; even better if Friday is a short day or a day off into the weekend. In a post earlier this week I mentioned
- [Wednesday Feature: Best Medicine](https://rhislop3.com/wednesday-feature-best-medicine/) - There is an age-old adage that laughter is the best medicine. I concur. We as a society, have lost our sense of humor (and our collective common sense). We take everything too seriously. No wonder depression is "up" along with loneliness. There used to be sitcoms on TV that were really quite funny. Not much
- [Are Independent Primary Care Docs a Thing of the Past?](https://rhislop3.com/are-independent-primary-care-docs-a-thing-of-the-past/) - The COVID pandemic illustrated a whole bunch of flaws, holes, and gaps within the U.S. health care system. To be fair, the pandemic illustrated flaws, holes, and gaps within U.S. society, government, the economy, etc. A trend that has been slowly moving forward seems to be accelerating through and post the pandemic and that trend
- [Hospice 2024 Final Rule and Home Health Update: Preserving Access Legislation](https://rhislop3.com/hospice-2024-final-rule-and-home-health-update-preserving-access-legislation/) - For early August, this is a semi-busy week with health policy stuff and upcoming econ data on inflation. Congress is on recess but that doesn't mean that there isn't a fair amount of activity in-play that will impact the health care industry, some positive, some negative. Likewise, this is the start of the presidential election
- [Friday Feature: COVID and Liability Insurance Coverage](https://rhislop3.com/friday-feature-covid-and-liability-insurance-coverage/) - A practice concentration within my business, H2 Healthcare, LLC, belongs to my wife who is also, the firm's Senior Partner and co-founder and co-owner. The practice area is compliance and a strong focus within, is litigation support/expert witness/forensic nursing. My wife is frankly, one of the foremost clinical compliance (nursing) experts in the nation, supporting
- [Wednesday Feature: Lonely at the Top](https://rhislop3.com/wednesday-feature-lonely-at-the-top/) - Last week, in a message from LeadingAge President, Katie Smith Sloan, she wrote about the epidemic of loneliness. Her words reflected on how leaders are prone to loneliness and how the same concept or concepts were addressed by Arthur C. Brooks in his book, "Strength to Strength". Surgeon General Vivek Murthy back in May, alerted
- [SNFs Get a Bit of Good News: CMS Final Rule for FY 2024](https://rhislop3.com/snfs-get-a-bit-of-good-news-cms-final-rule-for-fy-2024/) - SNFs got a little early Christmas present yesterday when CMS announced its Final Rule (PPS) for Fiscal Year 2024 (begins October 1, 2023). Instead of a 3.7% increase as proposed in the initial rule, CMS finalized a 4% increase (plus an additional 0.3%). Back in April, I wrote about the proposed rule. That post is
- [Senators Seek Survey Accountability for SNFs](https://rhislop3.com/senators-seek-survey-accountability-for-snfs/) - Last Thursday, Senators Bob Casey (Pennsylvania), Ron Wyden (Oregon), and Chucky Grassley (Iowa) sent a letter to CMS asking that the agency "take immediate steps to strengthen the nursing home oversight system". Their letter is a follow-up to a report from the Senate Committee on Aging, chaired by Casey, detailing a myriad of problems with
- [Friday Feature: GDP Report](https://rhislop3.com/friday-feature-gdp-report/) - Yesterday, the second quarter GDP report (economic activity) was released. This is the initial print from the Bureau of Economic Analysis. It will see two more prints but the initial one is always the headline story. Revisions of late, tend to be down versus up (improvement). I eschew the headlines for the details as the
- [Not Just Senior Living...Hospitals Too](https://rhislop3.com/not-just-senior-living-hospitals-too/) - Lately I've written a fair amount (multiple articles) regarding the economic conditions in senior living/post-acute care. The current economic headwinds of rising capital costs/interest rates, labor scarcity, rising costs due to labor scarcity and commodity inflation have caused providers to rethink many operating assumptions. Margins have eroded and often, decisions about additional volume via admissions,
- [Fed Rate Action and the Impact on Seniors Housing](https://rhislop3.com/fed-rate-action-and-the-impact-on-seniors-housing/) - Yesterday, the Federal Reserve raised its benchmark interest rate by .25 basis points (one quarter of on percent). The effective rate is now 5.25 to 5.50 percent. This is highest Fed Funds rate in 22 years. For the past multiple weeks, I have been writing on how the rate progress has impacted (negatively), seniors housing.
- [Wednesday Feature: Days Before Christmas](https://rhislop3.com/wednesday-feature-days-before-christmas/) - This is weird but the other day while I was working on my computer, a pop-up occurred telling me how many days were left until Christmas. I checked it out and it's a real site, a Christmas countdown clock. Here it is (if you don't believe me) https://www.xmasclock.com/ . Basically, we have 151 days (as
- [Senior Living Occupancy Trends - A Bit More Data](https://rhislop3.com/senior-living-occupancy-trends-a-bit-more-data/) - I've been closely watching the post-pandemic recovery of the senior care and living industries. In the past sixty days or so, I've written a number of articles/posts on occupancy recovery, factors impacting recovery, and factors that may further stress recovery trends. Within these posts/articles, reference material exists from sources like Fitch, National Investment Center
- [Senior Living and Care M&A: Two Worlds](https://rhislop3.com/senior-living-and-care-ma-two-worlds/) - In a report provided by Ziegler investment bank, M&A activity in the non-profit industry segment is "up" for the first half of the year, near record levels. The report suggests the pace will continue into the second half. Compare this data to report from Levin that deal activity was down significantly in the first quarter
- [Friday Feature: Home Health Proposed Rule Implications](https://rhislop3.com/friday-feature-home-health-proposed-rule-implications/) - Last month, CMS dropped the 2024 PPS Proposed Rule for Home Health. Like all other provider segments, Proposed Rules function to address primarily payment, then other programmatic issues/rules such as quality measures, data reporting, etc. The proposals generally mirror the final rules, but tweaks do occur. The payment end, however, rarely changes much as often,
- [Real Estate Sales Report Out - Dismal News for Seniors and Senior Housing](https://rhislop3.com/real-estate-sales-report-out-dismal-news-for-seniors-and-senior-housing/) - The June existing home sales report from the National Association of Realtors paints a depressing picture of the residential real estate market. The release is here: https://www.nar.realtor/newsroom/existing-home-sales-retreated-3-3-in-june-monthly-median-sales-price-reached-second-highest-amount Home sales down 3.3 percent Sales off 18.9% from a year ago Inventory available for sale didn't change - 2.8 months (seasonally adjusted) Median prices rose again to
- [Wednesday Feature: Nostalgia](https://rhislop3.com/wednesday-feature-nostalgia/) - Every once in a while, something sends me down memory lane. The other evening while sitting on the porch with my wife, she mentioned, "remember when, during the late news, a public service announcement would say, it's after 10:00 pm, parents, do you know where your children are?" We both laughed and bantered back and
- [Staffing Level Mandate - Update](https://rhislop3.com/staffing-level-mandate-update/) - In this year's final rule (PPS) for SNFs, CMS indicated that it would delineate proposals for final rule making this spring regarding mandated staffing levels. In the 2023 Final Rule, CMS solicited comment regarding staffing level mandates. In yesterday's post on labor and job data, I covered how incomplete the staffing picture remained for senior
- [Jobs Data and Staffing Status Update](https://rhislop3.com/jobs-data-and-staffing-status-update/) - With reports from the Bureau of Labor Statistics out this past week, the job market remains relatively strong and healthcare within the market, similarly strong. Unemployment remained at 3.6% and labor participation remained at 62.6% (same for last four months) and the percent of the population employed remained at 60%. For the month of June,
- [Friday Feature: The Good Acquisition](https://rhislop3.com/friday-feature-the-good-acquisition/) - Organizational expansion is truly a tale of two options (primarily): add capacity organically (build or start from scratch) or acquire an existing business. Both have pluses and minuses, but when it comes to scale on a more rapid basis and movement into a new market area, acquisition tends to make more sense versus an organic
- [Fitch, Life Plan Communities, Mid-Year Update](https://rhislop3.com/fitch-life-plan-communities-mid-year-update/) - In December of 2022, Fitch (credit rating agency) issued their outlook for the non-profit, Life Plan (CCRC) sector within the senior housing industry. Fitch outlooks are a primer for creditors seeking to determine lending scales for the upcoming year (bullish v. bearish). The Fitch outlook for the sector was "deteriorating". The basis for this negative
- [Wednesday Feature: The Gift of Giving](https://rhislop3.com/wednesday-feature-the-gift-of-giving/) - This past Monday, I played golf in a charity event, the proceeds of which, went to Children's Hospital of Wisconsin. The event, however, wasn't sponsored or produced by Children's Hospital. The event, now twenty-three years (next year, twenty-four), is the creation of a good friend of mine and ongoing business colleague, Jim Lombardo. Jim is
- [Blast from the Past: Healthcare Leadership...](https://rhislop3.com/blast-from-the-past-healthcare-leadership/) - Golf outing today for Children's Hospital of WI so a bit of recycling...I wrote this a number of years ago (April 2016) and it was very popular and resonates well today. Enjoy! The original post is here: https://wp.me/ptUlY-kf The bulk of my work centers around gathering data, analyzing trends and working with the leadership of
- [Friday Feature: Affordability is an Issue](https://rhislop3.com/friday-feature-affordability-is-an-issue/) - One of the largest complaints about senior care and housing is cost. It is or can be, darn expensive. The best, most amenitized Life Plan projects can run hundreds of thousands of dollars to enter and tens of thousands more in monthly fees. Rates inflate typically, more than CPI each year. Lately, rate inflation has
- [Wednesday Feature: Relentless Incrementalism](https://rhislop3.com/wednesday-feature-relentless-incrementalism/) - There is an old saying that goes like this: "How do you eat an elephant? One bite at a time." That is a succinct definition for relentless incrementalism. Doing the hard stuff in life is rarely a quick accomplishment. I've never run a marathon, but I know people who have, and I know they don't
- [Freedom is not Free](https://rhislop3.com/freedom-is-not-free/) - In the midst of a BBQ, fireworks show, or picnic today, take a moment to remember that freedom is not free. Freedom is earned and liberty protected and secured by those who believe deeply and are willing to sacrifice personally. God Bless America and Happy 247th! May there be many more...
- [Friday Feature: What Baby Boomers Want](https://rhislop3.com/friday-feature-what-baby-boomers-want/) - Soon the target customer for most senior housing options, primarily independent living and CCRC/Life Plan will be folks born in the "baby boomer" generation. Boomers are folk born between 1946 and 1964, placing them today, between 76/77 and 58/59 years of age. They were born right after WW II and right at the beginning of
- [Health Care Sector Econ Data Points](https://rhislop3.com/health-care-sector-econ-data-points/) - In its latest update, the Altarum Health Sector Economic Indicators, provided some interesting information on health care spending, job growth, and pricing. The data was released yesterday and is accessible here: https://altarum.org/publications/june-2023-health-sector-economic-indicators-briefs Some key data points from the report are as follows. The data is useful in forecasting, budgeting, and planning, especially in terms of
- [Wednesday Feature: Independence Day](https://rhislop3.com/wednesday-feature-independence-day/) - Happy Hump Day! Within less than a week, America's most significant holiday will occur - Independence Day. Celebrated on July 4th, this day commemorates the ratification of the Declaration of Independence by the assembled U.S. Constitutional Congress, in Philadelphia, declaring separation and independence from English (King of England) rule. The 4th of July became the
- [Mid-Year Update: The Economy and Capital Markets](https://rhislop3.com/mid-year-update-the-economy-and-capital-markets/) - Just a tick early as mid-year officially won't occur until this Saturday with the second quarter officially ending, Friday. This said, not much is likely to change the current status between now and Friday or for that matter, any time soon. The first half of 2023 can be summed up through a look at two
- [Friday Feature: 2 Court Cases](https://rhislop3.com/friday-feature-2-court-cases/) - As I close the week, I've been following a lot of legal news, specifically court cases involving health care and in one case, a decision from the Supreme Court. Legal news can be rather arcane and boring but, in some cases, the implications of decisions can be rather profound. Such is the case (no pun
- [Wednesday Feature: First Day of Summer!](https://rhislop3.com/wednesday-feature-first-day-of-summer/) - Happy Hump Day! Today is the first day of summer (northern hemisphere) otherwise known as the Summer Solstice. On this day, the sun is at its furthest northern rotational position providing maximum daylight north of the equator and minimal nighttime. On the first day of winter, the Winter Solstice, the inverse is true as the
- [Hospice Alert: Regulatory Changes Likely, Soon](https://rhislop3.com/hospice-alert-regulatory-changes-likely-soon/) - In a series of news stories starting with a piece in the New Yorker published last November, hospices, particularly for-profit hospices in certain states, are being called-out for fraudulent activity. The New Yorker article headline begins, "It began as a visionary notion—that patients could die with dignity at home. Now it’s a twenty-two-billion-dollar industry plagued
- [Friday Feature: MedPAC, Single Payment, and the IMPACT Act](https://rhislop3.com/friday-feature-medpac-single-payment-and-the-impact-act/) - The Medicare Payment Advisory Commission (MedPAC) via a report submitted to Congress on Thursday (yesterday) indicated that a single post-acute payment under Medicare is feasible but extensive policy procedural changes would be required to make it workable. The concept is that one uniform payment would apply to post-acute care delivered in home health, skilled nursing,
- [Blast from the Past - Duties of Boards: An OIG Perspective](https://rhislop3.com/blast-from-the-past-duties-of-boards-an-oig-perspective/) - There are nearly 300 articles/posts on this site and from time to time, I'm going to repost an "oldie but a goodie" that is as applicable now as it was when I originally wrote it. This is from July of 2009. This follows well with Tuesday's piece on OIG initiatives and SNFs...https://wp.me/ptUlY-BJ This seemed to
- [Wednesday Feature: Father's Day and Sunday Dinner](https://rhislop3.com/wednesday-feature-fathers-day-and-sunday-dinner/) - This Sunday (upcoming) is Father's Day. Father's Day, like Mother's Day, is a day singled-out on the calendar to celebrate the paternal role within the family - dad or father. By spending and activity however, the day receives less attention and recognition than Mother's Day. As a dad, I can understand that and relate to
- [OIG Initiatives for SNFs](https://rhislop3.com/oig-initiatives-for-snfs/) - On the heels of a report released in January of this year, the Office of Inspector General for the Department of Health and Human Services has created a series of regulatory reviews/quality initiatives for SNFs. The report focuses on the SNF experience during COVID and what, in the opinion of the OIG analysts, regulatory interventions
- [Owner's Rep - What It Is, When and How to Use One](https://rhislop3.com/owners-rep-what-it-is-when-and-how-to-use-one/) - Healthcare has a great deal of complexity in terms of care delivery and clinical needs. Today, and going forward, equal complexity exists on the business and operations front. Large provider organizations and systems are likely to have the capacity and capability to acquire and internalize, expertise within the organizational structure. Smaller, single site or regional
- [Friday Feature: Occam's Razor and Management](https://rhislop3.com/friday-feature-occams-razor-and-management/) - When I have coached/mentored executives and senior management, I am always initially surprised by how much these folk want to complicate things. Healthcare is notorious for bureaucracy and to a large extent, folks that have worked only in healthcare have been socialized that complex regulations and rules and then, organizational systems for compliance wrapped with
- [Supreme Court Decides: Nursing Home Residents/Families Can Sue Public Facilities](https://rhislop3.com/supreme-court-decides-nursing-home-residents-families-can-sue-public-facilities/) - This morning, the Supreme Court ruled that residents and their surviving heirs/family members can sue a publicly owned nursing home under the Federal Nursing Home Reform Act. The court upheld a lower court ruling against the Health and Hospital Corporation of Marion County (HHC). This organization operates publicly owned (governmental) SNFs in Indiana. A couple
- [Wednesday Feature: The Greatest Generation](https://rhislop3.com/wednesday-feature-the-greatest-generation/) - Yesterday was the 78th anniversary of Operation Overlord a/k/a D-Day. On June 6th, 1944 the Allied Forces comprised primarily of U.S., Canadian, and British forces conducted a series of beach front invasions along the Norman coast (French). The invasion involved 156,000 troops arriving on the beaches or via airborne units (paratroopers) and another 195,000 naval
- [SNFs Get Ready - Claims Audits Start Soon!](https://rhislop3.com/snfs-get-ready-claims-audits-start-soon/) - Recently, CMS announced that its Medicare Audit Contractors (MACS) would soon commence (June 5) a five-claim audit process for every nursing home in the nation participating in the Medicare program. The reviews are set to occur on a rolling basis whereby each MAC in its region, will begin by pulling five Medicare claims from each
- [Wednesday Feature: Summer's Here!](https://rhislop3.com/wednesday-feature-summers-here/) - This past weekend was the official, unofficial start of summer as Memorial Day weekend typically ushers-in the summer faves of barbecue, fireworks, picnics, parades, and warm days. I hope you all enjoyed the weekend and took a bit of pause from your fun to remember those special men and women that lost their lives in
- [Friday Feature: SNFs Still Make Sense](https://rhislop3.com/friday-feature-snfs-still-make-sense/) - For some recent years, enhanced by the pandemic, the role of SNFs in the post-acute/senior living industry has tarnished. Residents and families often view the SNF as a "negative place" to reside, even if for short-term recuperation. Clinical staff take a dim view of the care complexity such that the SNF is a downgraded clinical
- [Wednesday Feature: Memorial Day](https://rhislop3.com/wednesday-feature-memorial-day/) - Aside from the holiday and the weekend immediately prior marking the start of summer, Memorial Day is a significant holiday for many. Officially, it is a national holiday set aside to remember and mourn the deaths of service members, killed in the line of duty (while serving in the U.S. Armed Services). It is unlike
- [Home Health and Assisted Living: Compliance and Litigation Tips to Note](https://rhislop3.com/home-health-and-assisted-living-compliance-and-litigation-tips-to-note/) - A growth, if you will, opportunity for many Assisted Living facilities is caring for a more clinically complex resident or resident group. The clinical complexity is very much tied to additional medical and physical frailty, necessitating access at times to skilled nursing and therapies. Most Assisted Living facilities, especially those not affiliated with a national
- [Senior Housing and the Real Estate Market - Status](https://rhislop3.com/senior-housing-and-the-real-estate-market-status/) - While we are seeing incremental occupancy gains in senior housing, the increases are slow but steady. Is there a leveling-off point upcoming? Perhaps. Regardless, even with the recent history of gains, there is a reason to be a bit skeptical for some product types to continue to improve. My skepticism rests at the Independent Living
- [Friday Feature: 5 Important Leadership Principles](https://rhislop3.com/friday-feature-5-important-leadership-principles/) - Every successful organization shares a common trait - good or great leadership. I've written numerous articles on this topic and how the same is connected to employee retention, market share increase, brand dominance, and organizational wealth (balance sheet and cash flow). Fundamentally, organizations flourish under good leaders and flounder when leadership is poor or not
- [Wednesday Feature: Here's Comes Summer!](https://rhislop3.com/wednesday-feature-heres-comes-summer/) - I can feel it and smell it.... summer is coming. Every year at this time, it feels like it's taken forever, but soon, the warmer days and the longer days (hours of sunlight), erase the darker memories of dreary, cold days. Winter becomes a distant memory, replaced by a joyous desire to romp outside. Where
- [Insight: CEO Turnover](https://rhislop3.com/insight-ceo-turnover/) - During the pandemic and continuing somewhat through current, healthcare turnover has been on the rise. Nursing turnover (from direct care) and retirements exploded by mid-pandemic. Burnout was high as was job dissatisfaction. What became evident is the linkage between staff turnover and staffing difficulties along with COVID policy, and CEO turnover. While 2021 turnover was
- [Senior Housing/Senior Living Debt Review](https://rhislop3.com/senior-housing-senior-living-debt-review/) - Senior housing in the form of CCRCs, Independent Living and Assisted Living (including memory care) is a large user of debt financing. While equity has become more prevalent via increasing private equity interests in senior living, operators, especially non-profits, continue to rely heavily on bank and bond financing. Private equity and venture capital investment trends
- [Friday Feature: Three Trends to Watch](https://rhislop3.com/friday-feature-three-trends-to-watch/) - TGIF! This Friday, I'm focusing on three trends that I think, will have a major impact on healthcare and senior living for the balance of the year and likely, at least the first half of 2024. These trends are in no particular order. Banking and Credit Struggles: This past week, the Federal Reserve provided some
- [Senior Housing/Post-Acute Insurance Update](https://rhislop3.com/senior-housing-post-acute-insurance-update/) - With so much going on in the industry post-COVID, challenging labor markets, rising interest rate costs, high inflation, and supply chain issues still somewhat bothersome, insurers are rightfully skittish about senior housing and the post-acute environment. Of course, good provides with solid track records, high quality records, low to no recent claims, and evidence of
- [Wednesday Feature: Happy Mother's Day](https://rhislop3.com/wednesday-feature-happy-mothers-day/) - This upcoming Sunday is Mother's Day. Despite its commerciality, it does have a history dating back to the early 1900s. In 1908, Anna Jarvis in honor of her deceased mother, Ann Reeves Jarvis created the first U.S. version of Mother's Day. Ann Reeves Jarvis was an activist who founded Mother's Day Work Clubs. A staunch
- [Pastoral Care and Risk Management](https://rhislop3.com/pastoral-care-and-risk-management/) - In 2001, the Association for Professional Chaplains honored me with their Distinguished Service Award for my work in expanding the impact of professional chaplaincy and programs of pastoral care/ ministry in specialized healthcare settings. This was (and remains for me) a huge honor. Yet, since that time, a little over twenty years ago, programs of
- [Major Upgrade Needed: Care Coordination](https://rhislop3.com/major-upgrade-needed-care-coordination/) - I've been in and around healthcare for three plus decades and a concept that has always been front of mind for me is care coordination. This is something that is so important for a patient's well-being in terms of improved outcomes and satisfaction. It is also a real opportunity for cost improvement. Unfortunately, I've seen
- [Friday Feature: REIT Update](https://rhislop3.com/friday-feature-reit-update/) - Like all healthcare/senior housing investments during the pandemic, REITs experienced turbulence and stagnant growth. Coming out of the pandemic, the outlook has started to brighten but, challenges remain in adjusting REIT portfolios. The adjustments are fundamentally, selling under-performing assets within their portfolios. Rebounds in occupancy are providing some bright spots though assets within, remain a
- [Wednesday Feature: Lessons from a Cat](https://rhislop3.com/wednesday-feature-lessons-from-a-cat/) - Happy Hump Day! I am a cat fan and a cat dad. Ever since I can remember, cats have been part of my life. I love dogs too and have had a number as pets, but I am partial to cats. My wife and I share our spaces with two cats: Mac and Cheese. You
- [May 11 and PHE: Provider Alert](https://rhislop3.com/may-11-and-phe-provider-alert/) - On May 11, the COVID Public Health Emergency (PHE) is set to end and along with it, a whole slew of requirements end or change, and regulatory waivers applicable to the Public Health Emergency, the same (ending). The end of the PHE will have positive and negative impacts on providers of all types though some
- [Medicare Advantage/Part D Final Rule](https://rhislop3.com/medicare-advantage-part-d-final-rule/) - Early in April, CMS released the 2024 Medicare Advantage/Part D Final Rule and within, there are a number of interesting policy shifts that could benefit providers. The rule addresses a common practice that has been frankly, often abused by Med Advantage plans - prior authorizations or more commonly known as, "prior auths". The crux is
- [Friday Feature: The Economic Realities](https://rhislop3.com/friday-feature-the-economic-realities/) - For the past two years, as the pandemic emergency waned, and the U.S. and the rest of the world moved back to a more normalized business and social condition, the fallouts of a mish-mashed pandemic policy (federal, states, local) became evident. School closures with virtual learning impacted kids and their education performance (falling performance on
- [Top 5 Staff Retention Tips for a Tough Labor Market](https://rhislop3.com/top-5-staff-retention-tips-for-a-tough-labor-market/) - Recently, I wrote a post on recruitment in a tough labor market. Suffice to say, I have not in my three decades plus career, seen a tougher labor market for clinical staff (all staff in many regards). COVID had a lot to do with the shifting supply of labor, but I'll offer that health policies
- [SNFs: 3 Overnight Stay Requirement Returning](https://rhislop3.com/snfs-3-overnight-stay-requirement-returning/) - As the Public Health Emergency (COVID) ends, healthcare providers will revisit pre-pandemic policies as a slew of waivers expire. One waiver particularly impactful to hospitals and SNFs is the requirement of a 3 Overnight (3 Day Stay) for a patient to receive Part A Medicare benefits in a SNF. Recall, the rule pre-pandemic was that
- [Wednesday Feature: The Last Quarter of Life](https://rhislop3.com/wednesday-feature-the-last-quarter-of-life/) - Following-up on an emerging trend from last week, this post has nothing to do with healthcare, health policy, etc. It is meant to have readers think and enjoy. It's origin, at least to me, is from a good friend and colleague. Happy Hump Day! Most of us are now in the last quarter of our
- [SNFs and HHAs: A Common, Concerning Trend](https://rhislop3.com/snfs-and-hhas-a-common-concerning-trend/) - Current economic and government policy conditions have converged to create a concerning trend for home health and SNF providers. The trend for both segments is loosely known as "referral rejection". The number of referrals that both provider types are rejecting is up considerably since the start of the pandemic and for now, I see no
- [In-Depth: CCRCs First Quarter 2023](https://rhislop3.com/in-depth-ccrcs-first-quarter-2023/) - The smallest distinct segment of senior housing is Life Plan communities or CCRCs. Assisted Living, Independent Living and Skilled nursing, in each segment, dwarf the number of CCRCs yet, CCRC popularity remains and continues to grow, if ever so slowly. CCRCs run a gamut between large and small, entry fee to rental, with/without SNFs yet
- [Friday Feature: The Supreme Court and Medicaid Beneficiary Rights to Sue](https://rhislop3.com/friday-feature-the-supreme-court-and-medicaid-beneficiary-rights-to-sue/) - TGIF! In a little known but important case argued in November of 2022, the family of a Medicaid nursing home resident in Indiana began a suit against a publicly owned nursing home (originally 2016), Valparaiso Care and Rehabilitation. The nursing home is operated by the Health and Hospital Corp. of Marion County. The corporation's board
- [Top 5 Tips for Recruiting in a Tough Labor Market](https://rhislop3.com/top-5-tips-for-recruiting-in-a-tough-labor-market/) - I've done a number of presentations on the staffing challenges facing providers and how, certain strategies work and others don't in terms of recruitment and retention. Over my 30 plus years in the industry, I've had reasonable (ok, very good) success in building and retaining high-performing teams, including direct care staff. I've been fortunate to
- [Wednesday Feature: The Shot Heard Round the World](https://rhislop3.com/wednesday-feature-the-shot-heard-round-the-world/) - Happy Hump Day subscribers and readers! With best intentions met, every Wednesday I'll add a post totally unconnected to healthcare, health policy, economics, etc. These brief notes are the remnants of an old fun precedent I set for myself and my staff. They are meant to be inspirational, educational, and fun. Sort of a way
- [Executive Order - Staffing and Medicare Implications Update](https://rhislop3.com/executive-order-staffing-and-medicare-implications-update/) - Yesterday I wrote a post regarding a significant (and large) Executive Order coming via the Biden Administration concerning long-term care, child care, staffing in nursing homes, expanded supports under Medicaid for long-term care and childcare, etc. The post is here: https://wp.me/ptUlY-uM . While I have yet to obtain the text of the order, I have
- [Staffing and Turnover: Medicare Payment Implications?](https://rhislop3.com/staffing-and-turnover-medicare-payment-implications/) - This morning, I caught some reporting on the Biden Administration's plan to issue an executive order, a rather large order, that will include several provisions related to jobs and long-term care. Recall in recent articles on staffing on this site, I've noted that the Biden Administration and CMS are working on promulgating rules under Medicare
- [Medicare Claims, Audits, Denials and AI](https://rhislop3.com/medicare-claims-audits-denials-and-ai/) - AI or Artificial Intelligence has been in the news a lot over the past few months. ChatGPT is the program that I've seen the most about. Elon Musk has come forward warning of the advance of AI and its implications for societies. I've seen story after story about how AI has the potential to be
- [Friday Feature: Nursing and LTC](https://rhislop3.com/friday-feature-nursing-and-ltc/) - Each Friday (hopefully so), I will take a specific topic that has been in the news or been directly posed to me by a colleague or a reader and do a bit of a deep dive feature. This week it's the future of nursing or more directly, nurses in senior housing and long-term care. As
- [Econ Update](https://rhislop3.com/econ-update/) - In this new category of snapshots, I'll grab some data and headlines and offer a few insights on a topic. This week is full of key economic data regarding inflation. Reading through the data for many can be a bit daunting. Likewise, lots of the data is more geeky than useful in daily life and
- [SNFs: Compliance, Medicare Billing and RACs](https://rhislop3.com/snfs-compliance-medicare-billing-and-racs/) - Despite significant delays due to COVID, Phase 3 requirements of the "mega rule" are now in effect and one of the most unique elements for SNFs is the Ethics and Compliance requirement - 483.25. A good primer on the requirement is attached here. I have highlighted some key points relative to this post. SNF Compliance
- [15 minutes](https://rhislop3.com/15-minutes/) - Daily writing promptDescribe one positive change you have made in your life.View all responses Take 15 minutes each day to examine the day and record my gratitude for what the day has given. Work and news reflect too much negativity and loss. My 15 minute reflection counters the "daily negative".
- [Merge/Affiliation in the Cards?](https://rhislop3.com/merge-affiliation-in-the-cards/) - I pay close attention to economic trends and to the health care industry in general, as the same are applicable. One trend I'm watching quite closely is business consolidation and mergers/affiliations. In the general economy, a lot of consolidation is occurring post-pandemic. Restaurants are closing outlets (Red Lobster, Krispy Kreme, Burger King, etc.), retail outlets
- [Senior Housing Update - Q1](https://rhislop3.com/senior-housing-update-q1/) - The first quarter is now in the books (so to speak) and the trend for senior housing remains about the same, a little better but not back to pre-pandemic levels. With a softening real estate market principally due to low inventory levels and high interest rates (by comparison to the past ten years), we are
- [SNF Proposed Rule - 2024](https://rhislop3.com/snf-proposed-rule-2024/) - 'Tis the season for CMS to release updated payment and program rules for providers under Medicare. In the past week or so, we've seen releases for Hospice and Inpatient Rehab Facilities. A couple of days ago, CMS released the proposed 2024 rules/updates for SNFs (skilled nursing). The fact sheet for the release is available here:
- [Hospice Proposed Rule - 2024](https://rhislop3.com/hospice-proposed-rule-2024/) - Just about a week ago, CMS released their proposed payment rule for hospices, effective for the Federal Fiscal Year of 2024, beginning October 1, 2023. As readers likely know, these proposed rules are more than just payment rates, incorporating certain regulatory requirements that pertain to the program and Medicare participation (for providers). The rules are
- [Penny Wise, Margin Foolish](https://rhislop3.com/penny-wise-margin-foolish/) - There is a common business axiom, one I have used/repeated many times over: "You can't save yourself to a profit(able business)". In health care and in senior living/senior housing, challenges abound and almost daily, new ones arrive. Staffing is incredibly challenging, supply costs are rising, inflationary pressures have increased utility costs, investment portfolios are beat-up
- [Litigation Risk and Assisted Living Facilities](https://rhislop3.com/litigation-risk-and-assisted-living-facilities/) - As I mentioned in the prior two posts, litigation activity is on the increase, post-COVID, and some of the most fertile ground for plaintiff's counsel is Assisted Living. SNFs are still as targeted but as stays decrease and facilities improve care capability, the trend remains level, for the most part. Where perhaps, Assisted Living and
- [Litigation and Staffing: What to Know, What to Control](https://rhislop3.com/litigation-and-staffing-what-to-know-what-to-control/) - Following up from my last post regarding staffing and litigation risks, this post concentrates on "what we know" and "what we can control". For example, what we know is that there simply is not enough staff (clinical and even non-clinical) to fill a provider's vacant positions. The world in general knows this and the press,
- [Back in the Saddle](https://rhislop3.com/back-in-the-saddle/) - Absent a bit, I've been. COVID, a crazy health care landscape, new work, new engagements, tons happening and happened. Suffice to say though, the content is coming back. There are a few updates to this site. All (almost) of the old content remains. Browse as you wish. While over time, some content has become a
- [PDPM: First Blush Analysis](https://rhislop3.com/pdpm-first-blush-analysis/) - One quarter (three months and change) down and PDPM appears to be mostly positive for SNFs. CMS is reporting a higher average per diem payment level than under RUGs. Despite some added coding complexity, paperwork burdens are down for providers (two MDS' during most stays now vs. many under RUGs). Anecdotally, the industry is seeing
- [SNFs: Five Issues and Trends to Watch...NOW!](https://rhislop3.com/snfs-five-issues-and-trends-to-watch-now/) - The beautiful, fascinating thing about health policy in the U.S. is its cycle of evolution. It evolves, sometimes slowly and other times quickly but always, in a progressive (not in the political sense) direction. Providers today can be lulled to sleep (quickly) by the vacuum drone of big policy lectures, webinars, etc., easily thinking for
- [The Connection Between Quality and Revenue](https://rhislop3.com/the-connection-between-quality-and-revenue/) - In nearly all provider segments of health care, revenue maximization and integrity are directly tied to compliance and quality ratings. In home health, submission of quality data via the OASIS (known as HH CAHPS) is required. Agencies that fail to submit the required data experience reimbursement reductions of 2%. For SNFs, reporting of QRP data
- [SNF Proposed Rule for 2020](https://rhislop3.com/snf-proposed-rule-for-2020/) - Spring is the time when CMS starts dropping Proposed Rules for various health care provider segments. This past week or so saw update drops for IRFs, Hospice and SNFs. Recall, Proposed Rules are administrative law changes that CMS makes to existing provider regulations, typically covering reimbursement and some programmatic policy changes that tie to reimbursement.
- [Governance and PDPM: What Boards Need to Know](https://rhislop3.com/governance-and-pdpm-what-boards-need-to-know/) - I spend a good (ok, large) amount of time working with non-profit and privately held health care, post-acute and seniors housing organizations. Nearly all of my work is at the C-level and above and frankly, my career as an executive was there as well (25 plus years). Boards/governance bodies play a key role in the success and/or failure of
- [Follow-Up: Real Impacts of Poor Quality and Lax Compliance](https://rhislop3.com/follow-up-real-impacts-of-poor-quality-and-lax-compliance/) - About ten days ago, I wrote a piece regarding the negative impacts providers can expect (and receive) when quality of care and service combined with vigilance on compliance are not primary in and across their organizations. All too often, I hear companies and organizations that I work with, say they are committed to quality but by deeds, the evidence is
- [The Real Impacts of Poor Quality, Inadequate Compliance and Weak Risk Management](https://rhislop3.com/the-real-impacts-of-poor-quality-inadequate-compliance-and-weak-risk-management/) - A number of interesting information drops occurred this past week or so reminding me that from time to time, the obvious isn't always so obvious. The seniors housing and skilled care industry today is going through a rocky patch. A solid half of the SNF industry is severely hurting or struggling mightily due to Med
- [Home Health Final Rule: Rate Increases plus PDGM](https://rhislop3.com/home-health-final-rule-rate-increases-plus-pdgm/) - While I was in Philadelphia speaking at LeadingAge's annual conference, CMS released its 2019 Home Health Final Rule. As I wrote in an earlier post regarding the proposed rule, the topic of interest was/is a new payment model - PDGM. As has been the case across the post-acute industry, CMS is advancing case-mix models crafted around
- [Site Neutral Payment Update](https://rhislop3.com/site-neutral-payment-update/) - In early October, I wrote an article regarding CMS 2019 OPPS (outpatient PPS) proposed rule, specifically regarding site neutral payments. The purpose of the article was to address the site neutrality trend that CMS is on, streamlining payments to reduced location of care disparities for the same care services. Succinctly, if the care provided is
- [Don't Miss Event: Webinar on Reducing Rehospitalizations](https://rhislop3.com/dont-miss-event-webinar-on-reducing-rehospitalizations/) - A week from today, I am conducting a webinar on reducing/avoiding unnecessary rehospitalizations. With SNFs just experiencing the VBP impact (Medicare incentive or reduction) starting October 1, this event is extremely timely. I'll cover the health policy and reimbursement implications regarding rehospitalizations plus new QRP and QM updates. I'll also touch on PDPM implications. Some great
- [SNF QRP and What the Data Means](https://rhislop3.com/snf-qrp-and-what-the-data-means/) - Yesterday, CMS began posting the first elements from the Quality Reporting Program. There are five elements that contain data, compared to the national average. Percent of residents developing new or worsening pressure injuries Percent of residents experiencing one or more falls with major injury Percent of residents who had a functional assessment on admission and the
- [Post-Acute, Site Neutral Payment Upcoming?](https://rhislop3.com/post-acute-site-neutral-payment-upcoming/) - In the 2019 OPPS (outpatient PPS) proposed rule, CMS included a site neutral payment provision. With the comment period closed, the lobbying (against) fierce, it will be interesting to see where CMS lands in terms of the final OPPS rule - maintain, change, or abate. The one thing that is for certain, regardless of the
- [SNF Final Rule 2019: Key Points and Provisions](https://rhislop3.com/snf-final-rule-2019-key-points-and-provisions/) - Beginning yesterday, I've been following the news regarding CMS' annual issuance of Final PPS rules for providers. Of greatest interest is the SNF Final Rule as it includes a completely new payment system, departing from the RUGS IV, therapy-centric system currently in-place. I've read through the Final Rule (all 424 mind-numbing pages) and summarized what SNFs
- [SNF PPS Final Rule 2019](https://rhislop3.com/snf-pps-final-rule-2019/) - Yesterday I wrote a quick post regarding the news that CMS was about to issue the SNF Final Rule for Fiscal Year 2019. Today, the text is available. Official publication in the Federal Register is set for August 8th. Readers may access the text here: SNF 2019 Final Rule I will have analysis and more
- [CMS Final SNF PPS Rule for 2019: Increases plus PDPM](https://rhislop3.com/cms-final-snf-pps-rule-for-2019-increases-plus-pdpm/) - Late this afternoon, I caught news that CMS will release a number of Final Rules impacting post-acute providers over the next few days. Below is a quick summary of what is known for SNFs. I will update this information as I get access to the Final Rule. PPS rates (manual) to adjust by 2.4% (increase). A
- [Five Post Acute Axioms (Truisms)](https://rhislop3.com/five-post-acute-axioms-truisms/) - I read a lot - part of the job. I hear lots of conversations and participate in many in-person and online. Last week, I spent a few evenings with my rehab partner. Between he and my wife, with clients across the country, it was fascinating how the conversation regarding fortune or famine (providers) boiled down
- [Stuck in Neutral: Bundled Payments and Post-Acute Providers](https://rhislop3.com/stuck-in-neutral-bundled-payments-and-post-acute-providers/) - After CMS nixed the mandatory expansion provisions for Bundled Payments and reduced the metro areas participating in CJR (joint replacement), the prospects for post-acute provider involvement in non-fee-for-service initiatives (payments and incentives based on disease states and care episodes) went in to limbo. With a fair amount of excitement and trepidation building on the part of the
- [Interoperability and Post-Acute Implications](https://rhislop3.com/interoperability-and-post-acute-implications/) - I'm not sure how many of my readers are following the subject and CMS stance/policy on interoperability among providers but the concepts and resultant debate are rather interesting. I am trying to encourage as many clients and readers to tune-in on this subject as the implications are sweeping - positively and negatively. Interoperability in this
- [SNFs and PBJ Article](https://rhislop3.com/snfs-and-pbj-article/) - Attached is a link a to a good PBJ (payroll based journal) article. It covers the basic concepts of what is going on today with regard to staffing level reporting and the Five Star system. Recall, staffing as a domain, is one of the stars in this system. The article is posted here (re-published) with permission of
- [CMS Proposes Reintroduction of Pre-Payment Review for Home Health (with a twist)](https://rhislop3.com/cms-proposes-reintroduction-of-pre-payment-review-for-home-health-with-a-twist/) - In a memo set for release today, CMS is proposing to reintroduce pre-payment review (with a twist) for Home Health claims. The memo version is here: HHA Pre Payment Recall, CMS first introduced pre-payment review in August 2016, starting in Illinois. The process required agencies to submit claim-related data BEFORE receiving final payment or face an
- [Home Health and Hospice: Strategic Movement in an Evolving Market](https://rhislop3.com/home-health-and-hospice-strategic-movement-in-an-evolving-market/) - Last year 2017, was a bit of a "downer" in terms of mergers/acquisitions in the home health and hospice industry. Though 2017 was fluid for hospital and health system activity, the home health and hospice sectors lagged a bit. Some of the lag was due to capacity concerns in so much that health system mergers, if
- [CMS Proposes New SNF Payment Model](https://rhislop3.com/cms-proposes-new-snf-payment-model/) - Last Friday, CMS released the contents of its annual proposed rule updating the SNF PPS plus (as always), fine tuning certain related programmatic elements. Final Federal Register Publication is set for May 8. (Anyone wishing the PDF version may download it from the Reports and Other Documents page on this site or access it here
- [Is a Paradigm Shift Starting in Senior Living?](https://rhislop3.com/is-a-paradigm-shift-starting-in-senior-living/) - A number of years ago, post-acute/senior living analysts, etc. started warning of a coming paradigm shift for skilled nursing and home health. I started writing and advising about this shift well over a decade ago. The signs were obvious. Rapid expenditure growth as a percentage of Medicare/Medicaid outlays. MedPac warnings to Congress of rising profit margins in
- [SNFs and the Medicaid Conundrum](https://rhislop3.com/snfs-and-the-medicaid-conundrum/) - What do Morningside Ministries in San Antonio, Genesis Healthcare, Signature Healthcare, HCR ManorCare, and Syverson Health and Rehab in Wisconsin have in common? Answer: A terminal relationship with Medicaid. While Genesis isn't "dead" yet, it is fundamentally on life support with a stock price of $1.50 per share and a Medicaid payer mix averaging 73%. HCR ManorCare is
- [SNF Outlook: 2018/2019](https://rhislop3.com/snf-outlook-2018-2019/) - As 2017 closed, a number of projects kept me busy right up to the Christmas holiday. Among these projects was a focus on the SNF industry current and its fortunes going forward, principally driven by clients in the investment industry. With REIT troubles, portfolio defaults on the part of HCR and Consulate, Sabra divesting Genesis facilities
- [New Compliance/Survey Resource for SNFs](https://rhislop3.com/new-compliancesurvey-resource-for-snfs/) - It is rare that I push or endorse any product on this site. This is an exception worth making. http://hcmarketplace.com/survey-success-for-long-term-care The book is authored by my wife who also heads the Clinical Compliance practice within H2 Healthcare, LLC - the firm that I head. She is our Senior Partner as well as the firm's Chief
- [Medicaid Reform: Hope for Taming the Gorilla?](https://rhislop3.com/medicaid-reform-hope-for-taming-the-gorilla/) - A few weeks back, I wrote a piece regarding Medicaid and its ties to the fortunes (lack thereof ) of some the largest SNF provider groups. Today a high percentage of resident census connected to Medicaid as a payer source is the largest contributor to the flagging financial condition of Genesis, HCR/ManorCare, Signature, and others. With
- [The SNF 800 lb. Gorilla - Medicaid](https://rhislop3.com/the-snf-800-lb-gorilla-medicaid/) - There is an old joke/riddle that goes like this: "Where does an 800 lb. gorilla sit? Answer: Anywhere it wants to". For SNFs and REITs today, that gorilla is Medicaid. Sure, there are numerous industry headwinds that SNFs face in terms of financial performance; Rising percentage of Medicare Advantage patients as part of the payer
- [Bundled Payment Update](https://rhislop3.com/bundled-payment-update/) - CMS has released the text of the proposed rule with regard to bundled payment status (see my post from earlier today). The link is here - https://s3.amazonaws.com/public-inspection.federalregister.gov/2017-17446.pdf In summary, here are the high points. No advance of the cardiac and upper femur fracture/traumatic joint repair/replace bundles for 2018. The reason? As stated in my earlier
- [Bundled Payment Hiatus....or, Demise?](https://rhislop3.com/bundled-payment-hiatus-or-demise/) - Within the last few days, CMS/HHS sent a proposed rule to OMB (Office of Management and Budget) that would cancel the planned January 2018 roll-out of the (mandatory) cardiac and traumatic joint repair/replacement bundles. Specifically, CMS was adding bypass and myocardial infarction DRGs to the BPCI (Bundled Payments for Care Improvement) along with DRGs pertaining to
- [SNFs and Stranded Assets](https://rhislop3.com/snfs-and-stranded-assets/) - Lately I've written rather extensively on what is occurring in the SNF sector to (rather) dramatically shift the fortunes for companies such as HCR/ManorCare, Kindred, Genesis, Signature, et.al. and a series of REITs that hold SNF assets (physical). In addition to my writings, I've consulted/conversed with numerous investment firms concerned and interested in this shift. Underlying all of my
- [SNF Fortunes, HCR/Manor Care and Salient Lessons in Health Care](https://rhislop3.com/snf-fortunes-hcrmanor-care-and-salient-lessons-in-health-care/) - Long title - actually shortened. In honesty, I clipped it back from: SNF Fortunes, HCR/Manor Care, Five Star, Value-Based Payment, Hospitals Impacted Too, Home Health and Hospice Fortunes Rise, and all Other Salient Lessons for/in Health Care Today. Suffice to say, lots going on but almost all in the category of "should have seen it
- [SNF Outlook, REITs, Kindred and Where to From Here](https://rhislop3.com/snf-outlook-reits-kindred-and-where-to-from-here/) - As the title of this post implies, a review of the status of the SNF industry is as much about current issues begat by past issues influenced by an outlook that is finally, starting to congeal. Writing that (sentence) was convoluted enough and that is exactly, where the bulk of the industry issues are. To begin,
- [Hospice, Hospital Readmissions and Penalty Implications](https://rhislop3.com/hospice-hospital-readmissions-and-penalty-implications/) - Late yesterday, a reader (who also happens to be a client from time to time), posed this question to me. "When hospitals discharge to hospice and if the hospice has to readmit to the hospital, the hospital doesn't get penalized for the readmit? Is this true?" Since this question is not one that I have
- [Health Systems, Hospitals and Post-Acute Providers: Making Integration Work](https://rhislop3.com/health-systems-hospitals-and-post-acute-providers-making-integration-work/) - Early into the Trump presidency and health care/health policy is front and center. The first "Obamacare repeal and replace" attempt crashed and burned. The upcoming roll-out of the next round of bundled payments (cardiac and femur fracture) is delayed to October from the end-of-March target date. Logically, one can question is a landscape shift forming? Doubtful.
- [Seniors Housing/CCRC Outlook plus Lessons from Brookdale](https://rhislop3.com/seniors-housingccrc-outlook-plus-lessons-from-brookdale/) - Now that the real estate dynamics have shifted on-balance to par or better (majority of markets can liquidate inventory at stable or rising prices with constant or modestly increasing demand), the outlook for Seniors Housing (IL, AL and CCRC) is less murky. The recessionary of the last 7 to 8 years has lifted. What is visible, while still
- [IMPACT Act, VBP, Care Coordination and the SNF Landscape](https://rhislop3.com/impact-act-vbp-care-coordination-and-the-snf-landscape/) - Now into February, its time to take stock of the Post-Acute/SNF landscape, particularly as the same pertains to the evolutionary policy initiatives in-play and moving forward. To start, there is little evidence on the horizon of an all-out retreat on the policy changes begat by the ACA. While some framework is building to "Repeal and Replace"
- [SNF M&A: The Provider Number Trap](https://rhislop3.com/snf-ma-the-provider-number-trap/) - Over my career, I have done a fair amount of M&A work....CCRCs, SNFs, HHAs, Physician practices, hospice, etc. While each "deal" has lots of nuances, issues, etc. none can be as confusing or as tricky to navigate as the federal payer issues; specifically, the provider number. For SNFs, HHAs, and hospices, an acquisition not properly
- [Post Acute Resolutions for 2017](https://rhislop3.com/post-acute-resolutions-for-2017/) - With a new year upon us and (perhaps) the most amount of free-flowing health policy changes happening or about to happen in decades, it seems appropriate to create some simple resolutions for the year ahead. Similar to the personal resolutions most people make (get healthy, lose weight, clean closets, etc.), the following are about "improvements"
- [Webinar - Post-Election Healthcare Policy: What to Expect](https://rhislop3.com/webinar-post-election-healthcare-policy-what-to-expect/) - Join me as I host a one-hour webinar and conference call regarding post-election healthcare policy. The program/call is set for Wednesday, December 14 at 1:00 PM EST/noon CST. With uncertainty looming, providers are wondering what will change as the Inauguration approaches and a new Congress settles in. We will review the ACA, Medicaid and Medicare, and related
- [The Election is Over....Now What?](https://rhislop3.com/the-election-is-over-now-what/) - We knew that sooner or later, the first Tuesday in November would arrive and with that, a new President and changes (many or few) to Congress. The outcome certain, we move to uncertainty again concerning "what next"?...or as applicable here, what next from a health policy perspective. With Donald Trump the incoming President-Elect, only so
- [New SNF Conditions of Participation: Implementation Timeframes](https://rhislop3.com/new-snf-conditions-of-participation-implementation-timeframes/) - About ten days ago, I published a post regarding the new Federal Conditions of Participation for SNFs. This long awaited regulatory update includes new, revised, and existing regulations published in final rule form last week (October 4). The post is here for reference http://wp.me/ptUlY-kL The questions frequently asked regarding the new CoPs (since release) are around implementation dates. As readers will note, whether
- [CMS Releases Final Rule on SNF Conditions of Participation](https://rhislop3.com/cms-releases-final-rule-on-snf-conditions-of-participation/) - The long-awaited final rule on the revised/new SNF Conditions of Participation is set for publishing on October 4 in the Federal Register. The public inspection version is available now, including the comments from the Proposed Rule at this link: https://s3.amazonaws.com/public-inspection.federalregister.gov/2016-23503.pdf The whole document is over 900 pages. The salient portions that include the regulatory changes/summary
- [Post-Acute Providers and Narrow Networks: Join, Form or Wait](https://rhislop3.com/post-acute-providers-and-narrow-networks-join-form-or-wait/) - As alternative payment models expand and the options clarify, the post-acute segment of the health care spectrum faces a series of strategic questions, primarily; Join a network that exists or is forming be it part of an ACO, a SNP, a preferred provider organization in a Managed Medicaid state, or part of a bundled payment initiative
- [CMS Proposes Additional Bundled Payments: The Post-Acute Implications](https://rhislop3.com/cms-proposes-additional-bundled-payments-the-post-acute-implications/) - On July 25, CMS released a proposed rule to create additional bundled payments/DRG focused EPMs, targeted for July 1, 2017. The announcement/proposed rule is consistent with CMS' and the Administration's goal to migrate up to 50% of all traditional FFS (fee-for-service) payments to alternative models by 2018. As with the CJR (bundled payments for hip and
- [The Supreme Court, False Claims Act, and Implications for Providers](https://rhislop3.com/the-supreme-court-false-claims-act-and-implications-for-providers/) - Nearing the end of the Supreme Court session, the Court issued an important clarification ruling concerning the False Claims Act in cases of alleged fraud. In the Universal Health Services case, the Court addressed the issue of whether a claim could be determined as fraudulent if the underlying cause for fraud was a lack of professional certification
- [SNFs: Strategies to Mitigate Readmission and Rehospitalization Risk](https://rhislop3.com/snfs-strategies-to-mitigate-readmission-and-rehospitalization-risk/) - Across a number of regulatory elements beginning this year (May/June through October), hospitalization and readmission rates (to) post-hospitalization from SNFs will be measured and ultimately, factored into the SNF landscape via reimbursement penalties and Star ratings. Below is a quick summary of where and when the hospitalization/readmission issues come into play. CJR - aka bundled payments
- [Health Care Leadership: Why its Hard, Why Many Fail and What it Takes to Succeed](https://rhislop3.com/health-care-leadership-why-its-hard-why-many-fail-and-what-it-takes-to-succeed/) - The bulk of my work centers around gathering data, analyzing trends and working with the leadership of various organizations to implement strategy or more centered, strategies. The process is iterative, interactive and always fascinating. Throughout my career, I've worked within (virtually) every health care industry segment and seniors housing segment. I also counsel and have
- [Getting CCRC Feasibility Studies Correct ... and Other Studies as Well](https://rhislop3.com/getting-ccrc-feasibility-studies-correct-and-other-studies-as-well/) - In my consulting career, I've done a fair amount of feasibility work (market, economic, etc.). Similarly, I've done a fair amount of similar analyses, primarily related to M&A activity and/or where financing is involved (debt covenant reviews, etc.). Heck, I've even done some bankruptcy related work! I'm also queried fairly often about feasibility, demand, market
- [Bundled Payment Primer: SNFs](https://rhislop3.com/bundled-payment-primer-snfs/) - On April 1, implementation of the CMS expanded Bundled Payments for Care Improvement demonstration for hip and knee replacement (aka CCJR) begins. This phase takes the initial voluntary BPCI program and expands the concept on a non-voluntary basis to 67 metropolitan regions. See my post on the final rule here at http://wp.me/ptUlY-jh. Effectively, Medicare reimbursed knee and
- [RehabCare, Therapy Fraud and Lessons Not Quite Learned](https://rhislop3.com/rehabcare-therapy-fraud-and-lessons-not-quite-learned/) - This last week the Department of Justice and CMS announced a $125 million settlement with RehabCare, a subsidiary of Kindred Healthcare, regarding improper Medicare billing. As in virtually all cases of a similar nature involving false or improper billing to the Medicare program, this matter began with a whistleblower suit (insiders establishing False Claims Act violations
- [Bundled Payments: Final Hip and Knee Rule](https://rhislop3.com/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
- [Modern Health Care Risk Management](https://rhislop3.com/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
- [Upcoming Webinar: CMS Proposed Reform Rule for SNFs](https://rhislop3.com/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
- [CMS Releases Proposed New SNF Rule](https://rhislop3.com/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
- [Core Administrative Competency: SNF](https://rhislop3.com/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
- [SNFs: A New Era in Post-Acute Care Begins](https://rhislop3.com/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
- [Medicare, Billing Audits and Self-Disclosure](https://rhislop3.com/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
- [SNFs, Therapy Contracts and Fraud: Redux](https://rhislop3.com/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
- [SNFs, Therapy Contracts and Fraud: Another Warning and Example](https://rhislop3.com/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
- [Hospice: Risk/Reward for Institutional Growth](https://rhislop3.com/hospice-riskreward-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
- [Post-Acute Compliance 2015: OIG Targets](https://rhislop3.com/post-acute-compliance-2015-oig-targets/) - As is customary in late fall, the Office of the Inspector General (OIG) of the Department of Health and Human Services released its Fiscal Year work plan. As a reminder or preface, the work plan is the summary of investigations and focal areas the OIG plans to undertake in the upcoming fiscal year and beyond
- [Therapy, Medicare Fraud, Extendicare: Lessons for SNFs](https://rhislop3.com/therapy-medicare-fraud-extendicare-lessons-for-snfs/) - In mid-October, the Justice Department announced a $38 million settlement with the SNF chain Extendicare, resolving a series of Medicare False Claims Act violations. The violations involved improper billing for services supposedly provided, provided unnecessarily, or for care that was substandard. This series of violations included allegations of inappropriately billed therapy services; care billed for
- [SNFs: Five Competitive Strategies Worthy of Investment](https://rhislop3.com/snfs-five-competitive-strategies-worthy-of-investment/) - One of the top questions I'm asked by clients, readers, students, and interested parties everywhere is how can my organization excel in a competitive environment. In other words, how can I build my organization's value proposition such that the organization becomes the provider of choice in the market? My answer is always thematically the same:
- [SNFs, Therapy Companies, and Billing Risk](https://rhislop3.com/snfs-therapy-companies-and-billing-risk/) - Readers, followers (Twitter, etc.) and folks who have attended one or more of my industry conference presentations know that I routinely harp on the "risk/reward" relationship between SNFs and therapy companies (the contract therapy provides). Last year at LeadingAge's annual conference in Dallas, the principals from Theracore Management Group and me did a full session
- [CCRC Update 2014](https://rhislop3.com/ccrc-update-2014/) - Earlier this spring (a couple, three moths ago), I spoke at a marketing/P.R. conference and when my session was over, I sat and visited with a number of the attendees. My presentation was about value propositions and marketing; how to align your organization's core economic value components within a marketplace, within a customer segment. Within
- [CMS Announces Final Rule for Hospice Payments for 2015](https://rhislop3.com/cms-announces-final-rule-for-hospice-payments-for-2015/) - Yesterday, CMS confirmed the details of an earlier published proposed rule (May) set for publication on August 22, 2014 (final rule) regarding FY 2015 hospice payments. Anyone wishing a copy of the Federal Register text, please contact me as provided on this site (either via comment or contact info. in Author page). As is always the case
- [CMS Issues Proposed Home Health Rule for 2015](https://rhislop3.com/cms-issues-proposed-home-health-rule-for-2015/) - Just ahead of the Fourth of July holiday, CMS released its proposed home health rule changes for FY 2015. As common, the proposal includes rate changes/modifications and clarifications and adjustments to Conditions of Participation. The proposed rule continues a path for CMS and the industry of rate reduction/rate rebasing and movement toward greater emphasis on
- [SNFs: Five Compliance Issues to Pay Attention To](https://rhislop3.com/snfs-five-compliance-issues-to-pay-attention-to/) - I don't write a lot on compliance issues. Given the scope of my firm's practice in this area, maybe I should. My practice focus is more strategic, policy, research and corporate development while compliance is the purview of another Sr. Partner and it is our largest practice area (by full disclosure, this practice area is
- [Analysis: Kindred Pursuit of Gentiva](https://rhislop3.com/analysis-kindred-pursuit-of-gentiva/) - In news just released, Kindred (the post-acute, skilled, rehab and LTAcH behemoth) has made two separate offers to purchase control of Gentiva, the latest a $14 per share offer consisting of half cash, half stock ($7 and $7). An earlier offer of $13 per share was rejected and it appears the $14 offer will see
- [Hospice and the Medicare Choices Program: A Follow-Up](https://rhislop3.com/hospice-and-the-medicare-choices-program-a-follow-up/) - Below is a link to an article from Bloomberg Business Week regarding the Hospice industry and the Medicare Choices Program. My last post covered the elements of this CMS demonstration project. The link comes from the original piece written by Charles Elmore and published in the Palm Beach Post this weekend. Readers will note my
- [Hospice and the Medicare Care Choices Model: A Progressive Approach?](https://rhislop3.com/hospice-and-the-medicare-care-choices-model-a-progressive-approach/) - About a month ago (mid-March), CMS introduced a pilot program called the Medicare Care Choices Model. Basically, this pilot program will allow Medicare beneficiaries to access, via certain participating hospice organizations, dual benefits; hospice and curative treatments, concurrently. Under the current Medicare Hospice Benefit, a patient with a terminal illness or condition, certified likely to
- [Boards of Directors: Success, Mediocrity and Sometimes, Failure](https://rhislop3.com/boards-of-directors-success-mediocrity-and-sometimes-failure/) - As a follow-up to a recent post on Boards of Directors and corporate governance (http://wp.me/ptUlY-gq), this post addresses how boards promote success, can often drive mediocrity and in some cases prompt organizational failure. The take-away where success, mediocrity and failure occur isn't structure, terms or committees rather, a consistent excellence or break-down in terms of
- [Medicaid Case-Mix States: A Reader Question](https://rhislop3.com/medicaid-case-mix-states-a-reader-question/) - Recently, a reader asked me a question regarding which states still use RUGs III for their Medicaid case-mix payments. At the time, I honestly didn't know the answer completely. Based on a little research, I've outlined the RUGs status as I currently know it, across the states that utilize Medicaid case-mix. Note: Not all states use
- [SNF Caution: Medicare and End of Life Billing](https://rhislop3.com/snf-caution-medicare-and-end-of-life-billing/) - While this isn't a de novo trend, it is one that I am seeing again with frequency and thus, it bears/requires CAUTION. This trend is commonly referred to as Skilled until Death or End-of-Life Skilled. The reference in "skilled" is Medicare; delivering qualified skilled nursing or skilled therapy services (or combination thereof) with sufficient frequency
- [Doc Patch in the Works](https://rhislop3.com/doc-patch-in-the-works/) - Yesterday, the Speaker of the House (John Boehner) announced that a compromise is forthcoming to alleviate, for one year, the pending 24% payment reduction to the Physician Fee Schedule arising out of the current SGR formula. Ten days or so ago I wrote a post regarding a House bill that repealed the SGR but contained
- [Boards of Directors: Outside Looking In](https://rhislop3.com/boards-of-directors-outside-looking-in/) - Over the course of many engagements plus my years as an executive, I've addressed and been asked to address, the theme of effective governance, particularly at the Board level. To bring this topic into full context, one of my many "hats" that I wear (periodically), is as an advisor to graduate and post-graduate students working
- [House Passes Doc-Fix Bill Destined for Nowhere](https://rhislop3.com/house-passes-doc-fix-bill-destined-for-nowhere/) - Earlier today, the House passed a bill that repeals the SGR formula used to derive physician reimbursement under Medicare. For more specifics on the SGR, see a previous post I wrote at http://wp.me/ptUlY-ae . The legislation is title SGR Repeal and Medicare Payment Modernization Act. Unfortunately, the fate of the legislation is predestined as the bill
- [Amedisys Today: A Cautionary Tale](https://rhislop3.com/amedisys-today-a-cautionary-tale/) - Rarely do I write about a specific company as my work doesn't focus on individual companies per se, more on industries and the policy/economics of health care industry segments. Occasionally, a company's story typifies an industry flaw or trend or the same is illustrative of an endemic issue (Vitas for example). Amedisys' continued saga of
- [CCRC/Seniors Housing Outlook 2014](https://rhislop3.com/ccrcseniors-housing-outlook-2014/) - Using characterizations, 2013 was a year of gradual ascent for the industry but not necessarily, uniformly so. After a series of years preceding classified as industry malaise, occupancy began to trend forward and absorption rates stabilize. Industry wide, overall occupancy is hovering around 90% for CCRCs though again, this number is broadly misleading. Non-profit CCRCs, the
- [Decline in Hospice Demand?](https://rhislop3.com/decline-in-hospice-demand/) - In the last month and across a series of analyst calls (investment firms) that I field on a regular basis, a question repeats: Why is the demand for hospice declining? Of course the economist in me wants to opine in great detail about "demand" and what factors increase or decrease demand or, shift demand among
- [Home Health Focus: Gentiva/Harden and More](https://rhislop3.com/home-health-focus-gentivaharden-and-more/) - A couple of weeks ago, I wrote a post covering the Home Health PPS Final Rule for 2014. As I was writing that post, I simultaneously reviewed the Gentiva/Harden deal plus the recent quarterly earnings of Amedisys and Almost Family (plus their acquisition of SunCrest HealthCare). The earnings reports plus the analytics from these two
- [The ACA/Obamacare: Predictability and Practicality](https://rhislop3.com/the-acaobamacare-predictability-and-practicality/) - With all the news and among the conjecture, punditry and analysis that fits any twenty-four hour news cycle, I wondered with a few colleagues the other day, how predictable the events current with Obamacare were. Americans being who we are, our collective political memories and policy memories are short. I too, often find even the recent
- [CMS Releases Home Health Final PPS Rules for 2014](https://rhislop3.com/cms-releases-home-health-final-pps-rules-for-2014/) - Last Friday, CMS issued its final rules for 2014 Home Health PPS. As is typical within these final rules, earlier proposals are clarified and additional direction for the future becomes clearer. In this case, most people who follow the Home Health industry trends will find the continuation of prior year themes; rate reduction, episodic rebasing, additional reportable quality
- [Medicare Advantage Plans and HIPPS (SNF PPS) Codes](https://rhislop3.com/medicare-advantage-plans-and-hipps-snf-pps-codes/) - A topic that I receive queries about from time to time concerns the payment practices of Medicare Advantage (MA) plans as the same relates to traditional Med A coverage under the PPS system. Recently (earlier this year and then again in October, CMS issued some fairly vague guidance to the MA world regarding a requirement
- [Obamacare/ACA: Implications for Consumers](https://rhislop3.com/obamacareaca-implications-for-consumers/) - Having jumped around just a bit in the last few weeks "topically", this post may seem a bit disjointed. It is meant as a continuation of a series I've compiled on the various implications providers, consumers, etc. can/will experience under the Affordable Care Act (a/k/a Obamacare). Given the news cycle of late and the recent roll-out of
- [Debt Ceilings, Government Shutdowns and Health Policy](https://rhislop3.com/debt-ceilings-government-shutdowns-and-health-policy/) - Most of my readers know by now that I am an economist by training and formal education. My clients know this as well. The net result is that I've been queried, almost to death as of late, as to what this current round of Washington folly is really all about. Is it about the ACA?
- [The ACA, Funding Resolutions and the Shut Down](https://rhislop3.com/the-aca-funding-resolutions-and-the-shut-down/) - For readers approximating my age, a commercial slogan ties to the title of this post: "Is it real or is it Memorex". In this current round of Washington political maneuvering and on display dysfunction lies the question; is the ACA issue real or is it a tool for political posturing? Is this a real "red
- [Observation Stay Relief via Congress?](https://rhislop3.com/observation-stay-relief-via-congress/) - An issue that continues to confound the hospital and SNF industry is the growing use and thus, referral and coverage (Medicare) ramifications of observation stays. Fundamentally, and observation stay by current definition is a non-inpatient stay - an extended residence in an outpatient status. Truly, this a bifurcated problem or issue; hospitals wishing to avoid
- [QAPI: What's it all About?](https://rhislop3.com/qapi-whats-it-all-about/) - Last week I spoke at two joint provider-surveyor training conferences regarding QAPI or more specifically, how it really works and what it looks like in "real-time". QAPI is a new survey requirement for SNFs; fully expanded to Quality Assurance, Performance Improvement. Up until recently, SNFs were required by federal conditions of participation to have a Quality Assurance function,
- [Obamacare/ACA: Implications for Providers](https://rhislop3.com/obamacareaca-implications-for-providers/) - This is the second post of a four-part series on the status and implications of the continuing roll-forward/roll-out of the Affordable Care Act (aka Obamacare). In this post, the context is the implications for providers, given the evolving state of the ACA and some of the current uncertainty of its future. Important to note: Affirmatively, the
- [Obamacare/ACA: Where it is at, why and where next](https://rhislop3.com/obamacareaca-where-it-is-at-why-and-where-next/) - A number of my regular readers and clients routinely ask for my thoughts/analysis on where the Reform Act/Affordable Care Act/Obamacare is at, particularly in-light of the recent one-year delay in the employer mandate. Given the complexity of this subject and the scope of the overall law, a single post won't cover the subject adequately. In compiling
- [Assisted Living, PBS and the Lessons Learned](https://rhislop3.com/assisted-living-pbs-and-the-lessons-learned/) - Since last week, I've fielded a number of questions/inquiries stemming from the PBS segment on Assisted Living. Interesting, a number of the queries have come from sources tangential to the industry (policy folks, trade associations, advocacy groups, etc.). Thematically, these sources are looking for answers as to "why" and "what can be done". Aside from
- [Emeritus/PBS and a Window on Assisted Living](https://rhislop3.com/emerituspbs-and-a-window-on-assisted-living/) - PBS is planning on airing a segment tomorrow (Tuesday, July 30) on its program Frontline, highlighting Assisted Living care in the United States (titled "Life and Death in Assisted Living"). Much of the content focuses on Emeritus and other large, for-profit operators. A link to the PBS website follows as summary to the broadcast. http://www.pbs.org/wgbh/pages/frontline/pressroom/frontline-propublica-investigate-assisted-living-in-america/
- [Improving Real Estate Economy Leading to Improving Seniors Housing Trends?](https://rhislop3.com/improving-real-estate-economy-leading-to-improving-seniors-housing-trends/) - Among the improvement laggards in the current slow economic recovery was the real estate sector of the economy. Despite record low borrowing rates, home sales seemed stuck in neutral even as positive GDP growth resumed, modest gains in employment occurred, and consumer confidence improved. Starting late summer 2012 and accelerating in to 2013, the real
- [Reforming the Medicare Hospice Benefit](https://rhislop3.com/reforming-the-medicare-hospice-benefit/) - As a wrap to my two previous articles regarding recent fraud and False Claims Act suits and issues in the hospice industry, a concluding piece is warranted. As I have written before, the fraud issues and cases in the Hospice industry divide (though not equally) between the providers committing the fraud and an inferior Medicare Hospice Benefit
- [United States v. Vitas: The Impact and What Next](https://rhislop3.com/united-states-v-vitas-the-impact-and-what-next/) - On May 5, the U.S. Department of Justice released its most recent complaint (legal suit filed in Federal court) against Chemed, the corporate parent of Vitas. The complaint is a False Claims Act suit. Briefly for the uninitiated, a False Claims Act suit alleges that the Medicare provider knowingly (or unknowingly but once discovered, did
- [Hospice Tumult: The Beggining of the End?](https://rhislop3.com/hospice-tumult-the-beggining-of-the-end/) - Over the past couple of months or so, I've watched rather intently, the developing storm clouds in the Hospice industry. Suffice to say, what is now apparent takes the form of a perfect storm. For industry "watchers", the news regarding Vitas and the amalgamation of federal false claims act suits is a reflection on the
- [Home Health Outlook: 2013](https://rhislop3.com/home-health-outlook-2013/) - In spite of best intentions, wicked winter weather across the middle U.S. has kept me off-track a bit and thus, I haven't quite met my goal of having these all published by Valentine's Day. Below is my and my firm's consensus Outlook on the Home Health industry for calendar year 2013 (part FY 2014). Summary
- [Hospice Outlook: 2013](https://rhislop3.com/hospice-outlook-2013/) - The smallest provider centric benefit (by outlay) under Medicare is also one of the fastest growing in terms of expenditures and agency growth. Lately, it's arguably become the most controversial in terms of payment and expenditure growth correlated with fraud. In the past year, the industry saw multiple large-scale investigations and ultimately, legal actions and OIG/Department of Justice
- [SNF Outlook: 2013](https://rhislop3.com/snf-outlook-2013/) - As luck would have it, work interfered with my plans to have all of the industry outlooks for this year complete and published by February 1. Good news: Ground work is done now I just need to get to the writing and editing on a consistent basis. With any luck and a bit of fortitude,
- [Medicare Outpatient Therapy Rates: Part B](https://rhislop3.com/medicare-outpatient-therapy-rates-part-b/) - I have a schedule or table if you prefer, of 2013 Part B Therapy Rates applicable to common SNF codes. It is applicable as user selects, for the entire U.S. As rates are only available on a "guesstimated" basis right now and somewhat subject to slight modifications, the version is not 100% guaranteed. I do
- [2013 Medicare, Fiscal Cliff, Policy Outlook and More](https://rhislop3.com/2013-medicare-fiscal-cliff-policy-outlook-and-more/) - Happy New Year! Now that I'm back in the saddle, so to speak, and semi-organized after a holiday break and vacation the time has come to take a look at where health care is and what is setting the stage for 2013 (at least near term). Getting started, Washington remains unbelievably mired in dysfunction. So much
- [Healthcare Polar Express](https://rhislop3.com/healthcare-polar-express/) - With the Holidays fast approaching and me, heading into a break and a brief vacation, the time is right to recap the current health policy landscape. As the title states, now it seems as if the industry is riding on the Healthcare Polar Express; head first into the dark, cold, snowy north. Fiscal Cliff: Wow, what
- [Healthcare and the Fiscal Cliff](https://rhislop3.com/healthcare-and-the-fiscal-cliff/) - The Fiscal Cliff stories are everywhere and as a result, lots of misinformation, conjecture, and supposition of deals, no deals and what happens next abound within the media. The economist in me can't help but opine on the economics at stake but for this purpose, I'll take only a slice of the overall issues; a
- [False Claims Act: Providers Beware](https://rhislop3.com/false-claims-act-providers-beware/) - Lately I have fielded a growing number of questions regarding various applications/uses of the False Claims Act and Medicare billing inquiries. What is disconcerting about these inquiries is their source; too many from providers or provider organizations. One in particular arises out of an acquisition and this bears special note and comment which, I have
- [Policy News: A Black Friday Edition](https://rhislop3.com/policy-news-a-black-friday-edition/) - Full of turkey and the trimmings and avoiding any retail outlets, Black Friday seems perfect for a quick synopsis of what is happening with health policy. Fortunately, I've maintained a good inventory of "stuff" (not stuffing, though I have an inventory of that too) to cull for content. OIG on SNF Payments: This falls into my
- [Five Things Every Healthcare Executive Should Focus On: Updated, Revised](https://rhislop3.com/five-things-every-healthcare-executive-should-focus-on-updated-revised/) - More than two years ago I wrote a post regarding "five" things every SNF administrator should focus on and lo and behold, a reader asked late last week if I would revisit this subject. She (the reader) is not an SNF administrator so she asked if I could focus more globally; sort of a "best practices"
- [Health Policy News: Too Good to be Quieted by Election Coverage](https://rhislop3.com/health-policy-news-too-good-to-be-quieted-by-election-coverage/) - With all of the election news blaring (thank goodness the end is soon here), some important health policy issues have been somewhat lost in the milieu. Below is a quick summary of what has caught my attention as of late (a heads-up for readers). Medicare/SNF Class Action Settlement: This is profound on a number of
- [Fables, Tales and Job Reports](https://rhislop3.com/fables-tales-and-job-reports/) - Before too much rancor sets in among readers, I'll admit that my content has strayed just a bit lately from health policy, etc. to politics and economics. This too shall pass and rather quickly. This post is for a friend and reader who e-mailed me earlier about the ADP job report and what it means
- [One Week](https://rhislop3.com/one-week/) - One week from today is the national election for president, every seat in the House of Representatives, and one-third of the Senate. Additionally, there are numerous gubernatorial elections and local or state-wide races at issue. No other nation on the face of the earth affords, nay protects, the rights of all of its citizens to
- [Elections Have Consequences](https://rhislop3.com/elections-have-consequences/) - Heading into round 2 of a three round debate format (tonight), I think its time to put a few core concepts on paper (or e-media in this case) for folks to remember about this political season. My role or task here is not to be partisan (your decision suffices on this front) but to be
- [First Glimpse at ACO Results](https://rhislop3.com/first-glimpse-at-aco-results/) - A cornerstone of health policy arising from health care reform is the formation of Accountable Care Organizations. The premise is that an organizational structure focused on improving patient care and satisfaction, in a coordinated fashion, would improve quality and thus, reduce cost. The policy implication is that on a shared incentive basis, organizations at-risk, would
- [Presidential Debates and the Core of Health Policy](https://rhislop3.com/presidential-debates-and-the-core-of-health-policy/) - Tonight marks Round 1 in the three-part series of presidential debates. Why Round 1 is interesting, aside from the political points and positioning each side craves (in his favor) is that this round is supposedly focused on domestic issues. Deficits, tax policy, education and yes, health policy will no doubt work through each candidate's comments. As debates
- [Catching Up, Part II: Home Health and Hospice](https://rhislop3.com/catching-up-part-ii-home-health-and-hospice/) - As the week concluded (sort of), I'm about half-way back in terms of cutting through the stacks of research and notes that I compiled through August and into early September. While time away from work is necessary for my sanity, it certainly promotes insanity upon return. Below is Part II of "catching up", entirely focused
- [Catching Up Part I: Politics, Observation Stays, and Medicaid](https://rhislop3.com/catching-up-part-i-politics-observation-stays-and-medicaid/) - Off the golf course (reluctantly) and back to work. Last week was full of catching up and revisiting issues and reports. As promised before I went temporarily AWOL, here's Part I of at least two parts (maybe three) of issues that I am following. Politics and the First Tuesday in November: The conventions are done and
- [What's Trending: Back on Track....For Now](https://rhislop3.com/whats-trending-back-on-track-for-now/) - Finally, my plans and I collide again on a Friday afternoon and I'm somewhat back on schedule ... for now. With forecasted travel next week plus a touch of R&R time, it looks like I'll be back off-track before long. We'll see. Not a lot different on my dashboard as this week concludes. I'm pretty much awash
- [What's Trending: Catching Up](https://rhislop3.com/whats-trending-catching-up/) - Probably the biggest trend as of late is my tardiness in getting these posts out on-time...sorry. My end of the week (last week) got distorted as I needed to attend a meeting with regard to a Medicaid shift in Kansas from fee-for-service to "managed". As I have been through these conversions or switches before, it's
- [What'sTrending: A Tad Late](https://rhislop3.com/whatstrending-a-tad-late/) - Travel last week took me off schedule a tad so this post, normally scheduled for last Friday, didn't make it on-line until Monday. Below is the list of what I am trending (watching) followed by last week's Fall Outs (worth noting but not worth watching). Hospice Fraud Redux: This issue is one that I have
- [What's Trending: Last Friday in July](https://rhislop3.com/whats-trending-last-friday-in-july/) - Opening celebration at the Olympics is catching most of the buzz today and the Dog Days of Summer are definitely full-on. Still too much heat and not enough rain for my pleasure but August is around the corner and hopefully, some cooler weather. If nothing else, I can rely on the Olympics to alter my
- [CBO Releases Updated ACA Score](https://rhislop3.com/cbo-releases-updated-aca-score/) - Tuesday, the Congressional Budget Office released their updated score of the ACA post the Supreme Court ruling. Substantively, the only reason or need for an update is the Court's tweak concerning Medicaid expansion; allowing states to opt-out of expansion. See my post from earlier this week for a bit more information on the Court's ruling and
- [CBO Score on Post-Court ACA Implications Due Today](https://rhislop3.com/cbo-score-on-post-court-aca-implications-due-today/) - Later today, the Congressional Budget Office is set to release an updated "score" of the Affordable Care Act (PPACA) incorporating the decision of the Supreme Court. The fundamental reason for the update is the Court's decision to invalidate a provision within the Act that would have penalized states via reduced federal Medicaid funding should one or more opt
- [What's Trending: A Hot Friday Perspective](https://rhislop3.com/whats-trending-a-hot-friday-perspective/) - Seems every day this month has been hot and dry - could use a break from the heat and definitely, some prolonged rain. Within the past couple of weeks, I've traveled "rural" a bit and as a result, I have a different perspective on what farmers and ranchers in the middle-section of the country are struggling
- [An Omission from Friday](https://rhislop3.com/an-omission-from-friday/) - Every once in a while, I make a mistake (rare I think but others when asked, would convey a different sentiment). This gaff is really an omission; a missed thought from Friday's post on "What's Trending". In reviewing my notes (the mess that they can be), I noticed I forgot to include a "watch" tip for
- [What's Trending: A Friday the 13th in July Perspective](https://rhislop3.com/whats-trending-a-friday-the-13th-in-july-perspective/) - Back after a week of vacation (sort of) and then a week of scramble to catch up, here's the latest that I am watching and that I find trending from readers and clients. Medicaid and Health Care Reform: Oddly, this has been a Medicaid week for me on a number of fronts. The Supreme Court decision
- [Supreme Court Upholds the PPACA](https://rhislop3.com/supreme-court-upholds-the-ppaca/) - In a surprising ruling, the Supreme Court upheld the constitutionality of the PPACA, in its entirety. Earlier in the week I wrote that my view, substantiated via conversations with many insiders ranging from lawyers to professors to think-tank analysts, was that the Court would find the core of the law unconstitutional. My guess is that many
- [What's Trending: A New Feature](https://rhislop3.com/whats-trending-a-new-feature/) - By popular request, I've created a new feature to this site to cover issues and topics "in brief" that I am watching or in some cases, directly tangential to by engagement. Weekly, my inbox is awash in "what have you heard?", "are you seeing this?", "what's going on with?", etc., type questions. I do try to answer them
- [Senate Back and Forth on Psychoactive Medication Regs](https://rhislop3.com/senate-back-and-forth-on-psychoactive-medication-regs/) - Last week, Senators Kohl, Grassley and Blumenthal introduced an amendment to an existing FDA bill that would require the informed consent of nursing home patients or their legal surrogates before certain anti-psychotic/psychoactive medications were given. The target of this legislative initiative is to reduce the use of certain types of drugs commonly used to treat serious, chronic
- [SNFs: Its All About Quality Now](https://rhislop3.com/snfs-its-all-about-quality-now/) - Across a recent engagement that spanned a large system, wide geography and about a year's worth of work, I had the chance to reflect numerous times on "what" has changed in the post-acute arena, particularly applicable to SNFs, over my 30 years. Below I've organized my thoughts in "eras" or periods of time. Cost Based/The
- [CCRC Marketing Reality Check-Up](https://rhislop3.com/ccrc-marketing-reality-check-up/) - Periodically, the source for a post on this site is the accumulation of thematically condensed questions that I receive regularly and with frequency; what I now call the "buzz". While the "buzz" for me is fairly constant across the post-acute/seniors housing industry, the pitch does vary, sometimes daily but most often, weekly. I guess it just
- [CMS Reverses Course on Independent Consulting Pharmacists](https://rhislop3.com/cms-reverses-course-on-independent-consulting-pharmacists/) - In a move that most industry watchers including myself believed was unlikely to occur, CMS decided to reverse course on a proposal to require SNFs to have separate relationships for dispensing and consulting pharmacies/pharmacists. CMS publicized its decision yesterday. About a month ago in a post I wrote regarding post-acute trends (http://wp.me/ptUlY-aO ), I indicated that
- [Know Your Market, Know Your Value Proposition](https://rhislop3.com/know-your-market-know-your-value-proposition/) - Last October I wrote a post regarding the development of an Economic Value Analysis and how the same is important for marketing seniors housing and skilled nursing. A couple of weeks ago, I wrote a post regarding feasibility tests key to project success and targeted feasibility. Later this year, in October at Leading Age's annual conference
- [Financial Tests Before Additions, Renovations or New Construction](https://rhislop3.com/financial-tests-before-additions-renovations-or-new-construction/) - A frequent, recurring question that I field, especially for CCRCs and seniors housing providers is "what" financial feasibility tests are most important before a project is started or for that matter, financed. Given that capital is still relatively tight, project feasibility and key financial tests are today, critically important to assure the best financing terms available
- [Post-Acute Issues Worth Watching](https://rhislop3.com/post-acute-issues-worth-watching/) - In my recent work and across recent discussions, phone conferences, etc., I've encountered a thematic trend; a circle of issues or as in reference to geese, perhaps a gaggle. Doing a bit of research and sifting through notes written over the past few weeks, here is what is trending. Pharmacy: In October of last year,
- [Medicare SNF Rate Outlook](https://rhislop3.com/medicare-snf-rate-outlook/) - Literally fresh off of a significant rate adjustment/reduction in October (2011), Medpac (the Medicare Payment Advisory Commission) releases a recommendation for complete SNF payment overhaul. In their assessment of the SNF payment system under Medicare, Medpac concludes the following; Medicare payments to SNFs represent 23% of all revenues. Medicare (payer) as a share of SNF patient
- [Medicare Fraud and Why; Part II](https://rhislop3.com/medicare-fraud-and-why-part-ii/) - Last week I published a post regarding Medicare fraud that is occurring in the post-acute industry. The post is available at http://wp.me/ptUlY-ak . At the end, I indicated that I would provide a follow-up post; a closer piece more succinct on why the fraud trend is heating up and what the drivers for this trend are. In
- [Medicare, Fraud and Why: Perspectives on the Post-Acute Industry](https://rhislop3.com/medicare-fraud-and-why-perspectives-on-the-post-acute-industry/) - What never ceases to amaze me is the amount of post-news discussion that occurs when certain issues rise to the front-page (or near the front page). Seemingly, industry side-liners awaken and look in disbelief that one major provider organization or another is again, embroiled in some OIG investigation, lawsuit or official inquiry concerning their Medicare
- [Medicare Doc Fix Redux](https://rhislop3.com/medicare-doc-fix-redux/) - The failure of the Super Committee to achieve any measure of "go forward" spending reform left unresolved, a whole host of Medicare program spending messes, many of which will rear their ugly heads come January 1. While many lament the Committee's failure to resolve equitably, what is set to become automatic cuts, the truth of the matter
- [Hospice Census: Where's It At?](https://rhislop3.com/hospice-census-wheres-it-at/) - A common question I am fielding has to do with the current "no growth" pattern of hospice census; in some cases, decline is more operative of the pattern. Briefly, there are a number of factors at play, some recurring themes and some driven by more aggressive CMS intervention. The biggest culprit in the current no-growth
- [Current Policy Trends to Watch](https://rhislop3.com/current-policy-trends-to-watch/) - In response to a recent series of questions from multiple segments of the health care and post-acute industry plus my own experiences within the landscape of providers and policy makers, I've summarized a current list of policy trends "pay attention to". Medicare Cuts and the Super Committee: Nothing seems to loom larger or cast a
- [Post-Payment Reductions: Build a Revenue Model for Success](https://rhislop3.com/post-payment-reductions-build-a-revenue-model-for-success/) - Not too long ago I wrote a post for SNFs regarding "what to do" in preparation for October 1 rate reductions. Since then, I've fielded inquiries galore from all kinds of providers looking into a future that likely includes Medicare and certainly, Medicaid rate/payment reductions. In most cases, the answer that I provide is clearly
- [SNFs: What to do Now for October 1](https://rhislop3.com/snfs-what-to-do-now-for-october-1/) - As known by now, a lot of change is occurring with Medicare effective 10/1. Daily, I field questions from around the country regarding what exactly is happening and what if anything an SNF should do to "minimize" the impact. To a certain extent, at least as far as reimbursement reductions go, it is difficult and ill-advised
- [Post-Acute Outlook Post Debt Ceiling, Post Medicare Rate Adjustments, Etc.](https://rhislop3.com/post-acute-outlook-post-debt-ceiling-post-medicare-rate-adjustments-etc/) - OK, the title is a bit wordy and trust me, I could have included more "posts" but I think I got the point across. First, I'll admit to having a crystal ball however, the picture I see is a bit like the first (and only) television set I remember having as a kid: Not in
- [CMS Announces Medicare SNF Cuts: The Implication](https://rhislop3.com/cms-announces-medicare-snf-cuts-the-implication/) - On Friday, CMS released its Final Rule regarding FY 2012 SNF PPS reimbursement. The Final Rule implements a reduction or "cut" in SNF PPS payments equal to 11.1% or $3.87 billion. The 11.1% reduction is based on 2011 rates and spending/outlays. In their proposed final rule published in May, CMS alluded to the real possibility that
- [OIG on Hospice: Restructure Hospice Payments for SNF Residents](https://rhislop3.com/oig-on-hospice-restructure-hospice-payments-for-snf-residents/) - This past week, the OIG released a report that represents a more definitive study of hospice payments and utilization trends under Medicare. The report is effectively a follow-up to recommendations made in MedPac's annual report(s) to Congress. The report provides a review of OIG's analysis of the growth of Medicare covered hospice patients over the
- [Medicare SNF Cuts: Fact, Fiction, Probability](https://rhislop3.com/medicare-snf-cuts-fact-fiction-probability/) - In early May, CMS released its proposed rule for FY 2012 concerning Medicare PPS reimbursement for SNFs. As most followers of the industry from investors, to operators to developers know by now, CMS dropped a "bomb" to the industry indicating bluntly, a warning of a parity adjustment (reimbursement or payment reduction) of 11.3% or $3.94 billion. In
- [Accountable Care Organizations: A Post-Acute Perspective](https://rhislop3.com/accountable-care-organizations-a-post-acute-perspective/) - Suffice to say, I am behind in getting this post "out". My best intentions of a month or so ago were quickly dashed by other more pressing commitments. Nonetheless, I did read the proposed regulations as produced by the Department of Health and Human Services/CMS on April 7 and worked through a stack of research on the subject of Accountable
- [CMS, Proposed ACO Regulations and a Post-Acute Analysis](https://rhislop3.com/cms-proposed-aco-regulations-and-a-post-acute-analysis/) - Late last week, CMS (Centers for Medicare and Medicaid Services) issued the proposed regulations for Accountable Care Organizations (ACOs). As is typical with CMS and all things PPACA related, the document is nearly 500 pages. I have read and begun to digest (creating of course, indigestion) the entirety of the document. As I have prepared
- [When and Why Projects Go Bad: Traps and Pitfalls to Avoid](https://rhislop3.com/when-and-why-projects-go-bad-traps-and-pitfalls-to-avoid/) - Creeping slowly out of a period of recession where financing was nearly impossible to get, providers, operators and developers are starting to look favorably at new development and refreshment of existing properties and infrastructure. Though capital is less than free flowing, money is entering back into the long-term care and seniors housing world fluidly enough
- [MedPac Report to Congress: 2012 Recommendations](https://rhislop3.com/medpac-report-to-congress-2012-recommendations/) - MedPac (Medicare Payment Advisory Commission) just released its March report to the Congress on Medicare program and rate recommendations for the FY 2012 (beginning October 1, 2011). The full report is available in PDF form on the Reports and Other Documents page on this site. Below I've provided a summary of the key recommendations contained
- [The Unraveling of the PPACA](https://rhislop3.com/the-unraveling-of-the-ppaca/) - OK readers and requesters, I haven't gone, as Robert Frost wrote, into the "woods lovely, dark and deep" but I have been preoccupied by work and things familial. Sadly, energy wanes as one focuses intently on the delicate balance that is juggling a frenetic work schedule, a mile of other professional commitments, travel, and family.
- [RUGs IV Here to Stay!](https://rhislop3.com/rugs-iv-here-to-stay/) - The news we all hoped for came forth this afternoon, wrapped with a big bow just in time for the Holiday season - RUGs IV is here to stay. The House this afternoon passed a companion version of the bill passed in the Senate yesterday. President Obama is expected to sign the bill into law
- [MDS 3.0, RUGs IV, RUGs III, Hybrid: A 45 Day Review](https://rhislop3.com/mds-3-0-rugs-iv-rugs-iii-hybrid-a-45-day-review/) - Forty- five days past the October 1 conversion to MDS 3.0 and the interim RUGS IV payment groups and I still am getting a great deal of requests for analysis tools, questions on payments, liabilities, dates and rates for the Hybrid (RUGs III) groups, maps between RUGs III and RUGs IV, etc. While I lost
- [Presentation on Strategic Pricing for Senior Housing](https://rhislop3.com/presentation-on-strategic-pricing-for-senior-housing/) - I've posted a Power Point presentation one of my partners and I did at a trade show/conference last week. The title is "Strategic Pricing Strategies for Senior Housing" and it is available for viewing or download on the Reports and Other Documents page of the site (menu listing on the right).
- [Hospices Looking for Census Improvements: Add Some Innovations](https://rhislop3.com/hospices-looking-for-census-improvements-add-some-innovations/) - Most hospices I talk with are finding census gains difficult these days. As I've written before, a number of factors are conspiring at the moment to keep census somewhat depressed and referrals tough to come by. With a struggling economy, all providers are looking for paying patient days. Referrals that should (or would) routinely go
- [Hospice Contracts in SNFs: Survey Reminders for the SNF](https://rhislop3.com/hospice-contracts-in-snfs-survey-reminders-for-the-snf/) - Due to a fair amount of travel recently, I'm a tad behind in pushing out updates, etc. Despite my rather harried schedule, I have kept track of questions, issues, etc. and in the next week to ten days, I will endeavor to get caught up. Please know that I do appreciate the comments and questions
- [RUGs III to RUGs IV: The Core of "Need to Know"](https://rhislop3.com/rugs-iii-to-rugs-iv-the-core-of-need-to-know/) - In the past month with October 1 looming closer, I've been fielding lots of questions regarding the transition from RUGs III to RUGs IV. Instead of listing the questions and trying to recap my answers (my memory is good but not that good), I've settled on an overview or "summary"; the core of what SNFs
- [Due Diligence and Acquisitions: A Review of Common Pitfalls](https://rhislop3.com/due-diligence-and-acquisitions-a-review-of-common-pitfalls/) - A regular, although not necessarily routine, exercise that I go through is a re-evaluation of recent acquisitions in the senior housing/long-term care industry to see "how they are doing or performing" post transaction. Perhaps the primary reason that I do this is my curiosity regarding the effectiveness of the due diligence process and the accuracy
- [House Passes Jobs Bill Containing Enhanced FMAP](https://rhislop3.com/house-passes-jobs-bill-containing-enhanced-fmap/) - On a party line vote, the House of Representatives passed legislation euphemistically coined the "jobs bill". The $26 billion dollar legislation includes a $10 billion appropriation for state school budgets and $16 billion to continued the enhanced FMAP (Medicaid match) provided under the ARRA (Stimulus bill), set to expire on December 31. The vote was
- [Enhanced FMAP Funding Moving Through the Senate](https://rhislop3.com/enhanced-fmap-funding-moving-through-the-senate/) - On December 31st of this year, enhancements made to the Medicaid FMAP (Federal matching dollars) via the ARRA (Stimulus or American Recovery and Reinvestment Act) are set to evaporate. In a series of bills and other legislative initiatives throughout the spring and early summer, Congress has failed to extend funding to prevent the evaporation of
- [Compliance, the Courts and a Risk Reminder](https://rhislop3.com/compliance-the-courts-and-a-risk-reminder/) - In previous posts I've written about the need for providers in all industry sectors to fully understand the compliance and legal risks that are inherent to the appropriate industry sector, as well as to health care today in general. As someone who has been immersed in health care operations and health policy for the past
- [Medicaid Expansion and the PPACA](https://rhislop3.com/medicaid-expansion-and-the-ppaca/) - Article I wrote for the National Healthcare Reform Magazine on the implications for Medicaid as a result of the expansion provisions under the health care reform law. Click on the link below (or copy and paste) to view the article. http://healthcarereformmagazine.com/article/health-reform-and-medicaid-expansion.html
- [As the Home Health and Hospice World Turns: Part II](https://rhislop3.com/as-the-home-health-and-hospice-world-turns-part-ii/) - In Part I, I wrote about my last week's conversations, etc. regarding the home health industry, specifically Amedysis, the Senate Finance Committee inquiry, the industry impact via the PPACA and the likely consolidation and merger trends that are approaching. Suffice to say, not all of last week's news and conversations focused on the home health
- [As the Home Health and Hospice World Turns: Part I](https://rhislop3.com/as-the-home-health-and-hospice-world-turns-part-i/) - Sorry for borrowing (piece of) a soap opera title for this post but it is rather appropriate given the news that occurred over the past 30 days. Just this past week, I've been interviewed by two business newspapers and on the phone with an investment banking firm I consult with from time to time regarding
- [Doc Fix Survives, Medicaid Ehanced Match Doesn't](https://rhislop3.com/doc-fix-survives-medicaid-ehanced-match-doesnt/) - In another procedural vote on the revamped Jobs bill in the Senate, Democrats fell short of mustering 60 votes to end a Republican filibuster, effectively ending for now, legislative efforts to extend unemployment benefits. The vote count was 57 to 41 to continue debate. Dying with the extension of unemployment benefits are a series of
- [Senate Doubles Back on "Doc Fix" Legislation](https://rhislop3.com/senate-doubles-back-on-doc-fix-legislation/) - After a mid-week roadblock was established on a procedural vote all but derailing the American Jobs and Closing Tax Loopholes Act and the integrated provisions that included a "doc fix", the Senate doubled-back on Friday and passed a separate measure that patches the pending cuts (21%) in the physician fee schedule set for June 1.
- [Senate Sets Roadblock on Jobs Bill: Impact is Felt for Doc Fix and Medicaid Funding](https://rhislop3.com/senate-sets-roadblock-on-jobs-bill-impact-is-felt-for-doc-fix-and-medicaid-funding/) - Yesterday the Senate, via a procedural vote, set a roadblock on the continued track toward passage for the American Jobs and Closing Tax Loopholes Act. The original version, re-crafted by the House to lower the price tag and then sent to the Senate, found limited traction on Wednesday. Oddly enough, the House version effectively trimmed
- [RUGS-IV Still In Limbo](https://rhislop3.com/rugs-iv-still-in-limbo/) - As the Senate is set this week to take a vote on the American Jobs and Closing Tax Loopholes Act (see my related posts), a key provision within the legislation having to do with implementation of the SNF payment system known as RUGs-IV remains in limbo. The PPACA (health care reform bill) required implementation of
- [American Jobs and Closing Tax Loopholes Update](https://rhislop3.com/american-jobs-and-closing-tax-loopholes-update/) - Prior to the Memorial Day recess (holiday), the House passed its re-shaped version of the bill. The re-shaping primarily involved spending constraints; reaction to wide-spread criticism (public) of current (and recent) Congressional deficit spending binges as well as a realization that fall elections draw ever closer. Specifically, what the House did was: Abandoned any additional
- [Improving the Quality of Care in Nursing Homes Act of 2010: S 3407](https://rhislop3.com/improving-the-quality-of-care-in-nursing-homes-act-of-2010-s-3407/) - Wisconsin Senator Russ Feingold introduced a bill today targeted at "improving the quality of care in nursing homes". The bill was introduced by Feingold in response to the efforts of the Wisconsin Association of Homes and Services for the Aging (WAHSA - non-profit, industry trade association) to have the federal government investigate the wide discrepancies
- [American Jobs and Closing Tax Loopholes Act - HR 4213](https://rhislop3.com/american-jobs-and-closing-tax-loopholes-act-hr-4213/) - Funny title that is rather misleading given the gravity of the health care/post-acute care provisions that are included in this bill. As is the case in Washington, especially these days, important health care provisions not addressed in the PPACA are coming forward in other bills; particularly bills involving unemployment benefits and COBRA benefits, etc. Such is
- [Senior Living/Housing M&A and Fitch](https://rhislop3.com/senior-livinghousing-ma-and-fitch/) - The title of this post likely appears a tad bifurcated but as you read through it, the title should make a bit more sense. In the past two weeks, I've had numerous conversations with potential buyer's looking at or for (to acquire), senior housing projects (AL, IL, some CCRC and a few SNFs). Invariably, the conversations
- [Five Things Every Administrator Should Focus On](https://rhislop3.com/five-things-every-administrator-should-focus-on/) - I had a phone conversation earlier today with a friend and colleague (he's part owner of a rehab consulting and management company) and as we talked, the conversation reminded me about the host of issues facing health care administrators. Our conversation flowed to long-term care and specifically, SNFs (he spends a lot of his time
- [Research Project: How much did your organization spend on H1N1 preparedness?](https://rhislop3.com/research-project-how-much-did-your-organization-spend-on-h1n1-preparedness/) - My firm (Grubb & Ellis/Apex Healthcare) is conducting a quick and simple research project, surveying health care providers regarding the costs incurred during their preparation for the H1N1 pandemic that never occurred. We'd like anyone from a hospital, nursing home, assisted living facility, hospice, home health agency, physician's practice, ambulance service, etc. to give us a brief
- [GAO Releases Report on Poor Perfoming Nursing Homes](https://rhislop3.com/gao-releases-report-on-poor-perfoming-nursing-homes/) - In 1998, CMS created the Special Focus Facility initiative or program designed to target or focus attention on improving the poorest performing facilities (performance defined by survey/compliance history). Each state selects up to 15 of the poorest performing facilities until the program reaches its cap or maximum of 136 facilities. The requirements from CMS to
- [Health Reform Implications for Institutional Providers](https://rhislop3.com/health-reform-implications-for-institutional-providers/) - My last post covered CMS' proposed rule affecting LTAcHs in fiscal year 2011 (October 1, 2010). In this post I noted that CMS' proposed rule included a disclaimer that any impacts related to the PPACA (health reform) were not included and as a result, CMS would from time to time, release updates providing additional guidance.
- [CMS Proposed Policy and Rate Changes for LTAcHs](https://rhislop3.com/cms-proposed-policy-and-rate-changes-for-ltachs/) - Yesterday, the Centers for Medicare and Medicaid Services (CMS) released its proposed rule for rates and other policy changes for FY 2011 (October 1, 2010) as applicable to Medicare inpatient stays within long-term acute care hospitals (LTAcH). The entire rule can be found at http://www.federalregister.gov/inspection.aspx#special. In their release, CMS noted that the proposed rule does
- [Stark, Health Care Reform and Updated Compliance Requirements](https://rhislop3.com/stark-health-care-reform-and-updated-compliance-requirements/) - When the Patient Protection and Affordable Care Act (PPACA) became law, a provision within adds a new dimension to the rules on self-referral and refund requirements of overpayment (Medicare) contained within the Stark Law. Specifically, the PPACA requires the Secretary of HHS to develop a new self-disclosure protocol whereby health care providers can disclose known (or found)
- [Part B Therapy Cuts Delayed to June 1](https://rhislop3.com/part-b-therapy-cuts-delayed-to-june-1/) - As a follow-up to a post from last week regarding pending cuts in Part B therapy rates, last evening the House passed a bill that the Senate had passed earlier in the day, included within is a provision to delay the pending cuts to the physician fee schedule until June 1. The provision is tucked
- [Part B Therapy Rate Reductions Return](https://rhislop3.com/part-b-therapy-caps-return/) - With Congress on recess, the temporary extension of the Part B therapy rate cuts ended on March 31. As of today, with Congress still on "holiday", the Part B therapy rate cuts remain in effect. Best knowledge has it that Congress is working on another temporary extension that would retro to April 1 and last through April 30.
- [Health Care Reform and Assisted Living](https://rhislop3.com/health-care-reform-and-assisted-living/) - In a bit of an indirect manner, Assisted Living got a boost from health care reform, albeit in a typical governmental fashion. With the Feds willing to use Medicaid as the vehicle for expanded coverage programs for underinsured (those within 150% of the poverty limit with high-deductible plans) and the uninsured, coupled with additional funding for Home
- [Health Care Reform Implications: Home Health Care](https://rhislop3.com/health-care-reform-implications-home-health-care/) - I'm a tad behind where I hoped to be in terms of getting these posts out. Its been a bit busy over the last ten days or so but headed into the Holiday weekend, a break in the schedule affords me the opportunity to "maybe" get caught up. Of all of the industry sectors touched by
- [Health Care Reform Implications: SNFs](https://rhislop3.com/health-care-reform-implications-snfs/) - The following is a summary of the major provisions in the recently passed health care reform bill. Please note: I have not attempted to cover every nuance in detail but to provide a highlight for a point of reference. If any reader has additional questions or wants additional insight on any particular provision, please let
- [Strategies for Accomplishing New Development or Major Capital Projects](https://rhislop3.com/strategies-for-accomplishing-new-development-or-major-capital-projects/) - One of the focal areas of my consulting practice/work is assisting health care organizations in accessing sources of funding (securing financing basically) for major projects and/or new development. Given the state of the economy, most specifically the capital markets over the past eighteen months, getting funding for capital projects and/or development has been challenging, though
- [Health Care Reform Implications: Medical Device and DME](https://rhislop3.com/health-care-reform-implications-medical-device-and-dme/) - Over the next few days I'll be pushing out a series of posts as my schedule permits, on the implications of health care reform for various industry segments. These are not meant as in-depth analyses, more of a "summary" of the key points. Reconciliation Act: This Bill has yet to pass the Senate and as a
- [The Housing Market and CCRC Prospects: What Each Means to the Other](https://rhislop3.com/the-housing-market-and-ccrc-prospects-what-each-means-to-the-other/) - It has been a world-wind few days (make that a week) analyzing all that is or was, health care reform. In some respects, I'm glad that the meat of health care reform is done for now though admittedly, I'm disappointed at the outcome. Suffice to say, I will catch-up on the ramifications of the legislation
- [Health Care Reform Updates and Analysis](https://rhislop3.com/health-care-reform-updates-and-analysis/) - I am writing various updates and analysis on the health care reform legislation as it moves toward a potential weekend vote in Congress on the Apex Healthcare E-News site. Readers can follow this link to read my analysis http://wp.me/PD9Ac-3A. Check back often throughout the next few days as comments/updates will be added as important news
- [Hospice Census Issues: A Possible Trend with a Twist?](https://rhislop3.com/hospice-census-issues-a-possible-trend-with-a-twist/) - Lately I've been running across intermittent publications/blog posts, etc. regarding a general decline in hospice census. At the end of this post, I've attached a couple of links for anyone who wishes to see some examples of what I've been reading. Naturally, being the curious consultant and health policy junkie that I am, I started
- [Medpac Report to Congress: 2011](https://rhislop3.com/medpac-report-to-congress/) - Earlier this week, Medpac (Medicare Payment and Advisory Commission) released its report to Congress. Primary among Medpac's duties is its provision of recommendations regarding payment updates under Medicare. Below, I have broken out and summarized the recommendations. Hospice (the points below the first bullet are continued recommendations from 2009) 2011 rate is the market-basket less a
- [Hospital Re-Admissions: Update to an Earlier Post](https://rhislop3.com/hospital-re-admissions-update-to-an-earlier-post/) - Last week I wrote about hospitals using "observation stays" as a means of dealing with the potential risk of reimbursement penalties imposed by CMS for certain re-admissions. The focus of my post was on how the trend of hospitals using observation stays to avoid CMS scrutiny (and penalties) was impacting Medicare admissions at SNFs. I
- [Hospital Observation Stays Impacting Medicare SNF Admissions](https://rhislop3.com/hospital-observation-stays-impacting-medicare-snf-admissions/) - An issue that I am fielding a fair number of inquiries about lately involves Medicare patients spending more than three days in a hospital, subsequently 'discharged' to a SNF and the SNF learning later that the patient was never technically admitted to the hospital. Mostly, the inquiries I am getting are along the line of "what's
- [Property Tax Update for Wisconsin Senior Housing](https://rhislop3.com/property-tax-update-for-wisconsin-senior-housing/) - The 2009-2011 Wisconsin budget (Act 28) incorporates a specific change to how the state defines property tax exemption for non-profit senior housing projects. Up to this point, the existing statutory law was vague and providers were left to contend with a precedent set by an even more vague Supreme Court decision (Columbus Park) and patchwork
- [New HIPAA Provision Now in Effect](https://rhislop3.com/new-hipaa-provision-now-in-effect/) - In August of 2009, the Department of Health and Human Services issued an interim final rule requiring that all HIPAA covered entities and their business associates develop notification requirements for a breach of unsecured protected health information (PHI). These new requirements are part of the Health Information Technology for Economic and Clinical Health Act (HITECH). In
- [Hospice Contract Reminders for SNFs](https://rhislop3.com/hospice-contract-reminders-for-snfs/) - On a fairly routine basis, I run across SNF Administrators and Directors of Nursing that continue to have issues with hospice patients in their facilities but not from the standpoint of the patient typically; from the standpoint of dealing with the Hospice and the terms of the contract between the Hospice and the SNF. In
- [CCRC Update](https://rhislop3.com/ccrc-update/) - Within the past ten or so days, I took some time to review the financial and operating benchmarks for CCRCs. The past eighteen months have likely been the toughest operational and financial period ever for CCRCs. By the end of 2009, a small rebound in the economy via an increase in existing home sales, a
- [Non-Profit Health Care Outlook for 2010](https://rhislop3.com/non-profit-health-care-outlook-for-2010/) - Moody's Investor Service released their annual sector outlook today for not-for-profit health care organizations, stating that they (Moody's) continue to maintain a "negative" outlook on the industry. Important to note in this report is that the focus is principally on hospitals and since the report is produced by Moody's, its primary perspective is on credit
- [Assisted Living Update](https://rhislop3.com/assisted-living-update/) - As 2010 comes in and looking back on 2009, the Assisted Living market has been on a bit of a roller-coaster. Without question, the downturn in the economy caused some provider pain most notably among some of the larger, heavily leveraged companies (e.g. Sunrise and Sunwest). Occupancy rates were soft in many parts of the country,
- [Sharpen the Sales and Marketing Efforts in 2010](https://rhislop3.com/sharpen-the-sales-and-marketing-efforts-in-2010/) - I lost track this past year of how many people I talked to that told me that, "organizationally, we are kind of stalled in developing new business because of the economy and health care reform". I know that in down economic periods, promotion budgets (advertising, sponsorships,etc.) are some of the first line items trimmed but
- [CMS Releases Annual Report on Health Spending](https://rhislop3.com/cms-releases-annual-report-on-health-spending/) - Earlier today, CMS released its annual report on national health spending for the year 2008. In summary, health spending grew at a rate of 4.4% (over 2007), equating to a per capita cost of $7,681 and a total cost of $2.3 trillion. This rate of growth, per CMS, is the slowest increase since 1960 although
- [Better Productivity, Better Retention: Labor Strategy for 2010](https://rhislop3.com/better-productivity-better-retention-labor-strategy-for-2010/) - For the vast majority of providers, productivity and retention are ongoing labor hassles. Salaries and benefits are typically, the single largest expense item for health care providers and when analyzed by all of the components, a surprising percentage is allocated for labor related expenses that can and should be, reduced. Expenses such as Worker's Compensation, recruitment, turnover,
- [Health Care Reform: The Senate, the President and the Truth](https://rhislop3.com/health-care-reform-the-senate-the-president-and-the-truth/) - In an effort to salvage some hope for the flagging Senate health reform bill and to provide sustenance for the neutered Harry Reid, President Obama convened all Democratic senators at the White House earlier this week for a strategy session. Per Mr. Obama, this activity was not a roll call to establish a majority but
- [CCRCs: Ready, Set, Market!](https://rhislop3.com/ccrcs-ready-set-market/) - As we head now into the new year, it makes sense for CCRCs to pre-ordain the recovery just a bit and move back into a modest-aggressive posture, qualifying and securing new residents. Even with a glimmer of light at the end of the tunnel, no CCRC owner/operator should expect there to be a great deal of pent-up demand. Seniors aren't monitoring CCRC opportunities and the market and economic conditions favorable for sales - that frankly is the CCRC's job. In order to get "back in the game" so to speak, a CCRC's marketing approach may need to be tactically tweaked. The next generation of marketing plans will need to be different, for quite some time, from those of say two years ago.
- [Health Care Reform: Back to the Senate and All that Jazz](https://rhislop3.com/health-care-reform-back-to-the-senate-and-all-that-jazz/) - Watching this reform process, at least for me, is now like watching a Ping Pong match or a Nascar race (sorry Nascar fans); back and forth and round and round. Even for someone who watches and interprets health policy for a living, this stuff is getting boring, monotonous and frankly, now somewhat nauseating, content wise. Maybe the
- [House Approves Doc Payment Fix](https://rhislop3.com/house-approves-doc-payment-fix/) - Last night via a 243 to 183 vote, the House approved a bill that would stave off the projected 21% cut in physician (fees) reimbursement under Medicare, set for January 1, 2010. The "Doc Fix" has been a hot-button issue within the health care reform debates as both the House and the Senate have not been
- [Medicaid and Health Care Reform](https://rhislop3.com/medicaid-and-health-care-reform/) - With so much discussion and news review on Medicare spending and health insurance reforms at the center of the health care reform debate, Medicaid has taken a back-seat in terms of analysis on its programmatic impacts. Today, Medicaid costs 76% of the cost of Medicare and covers approximately 20% of the population. In the recently
- [Health Care Reform: Getting to the Details](https://rhislop3.com/health-care-reform-getting-to-the-details/) - Its been about ten days since the House passed its version of health care reform and just now, it is possible to unwind and assess some of the cost/price details that are buried within the 2,000 page bill. Similarly, it is also possible for the general public to begin the process of digesting the ramifications
- [Health Care Reform in the House: A Post Mortem](https://rhislop3.com/health-care-reform-in-the-house-a-post-mortem/) - Late Saturday night by the slimmest of margins, the House of Representatives passed H.R. 3962 otherwise known as the Affordable Health Care Act for America - three votes the other way and the Bill would not have passed. The Bill weighs in at over 2,000 pages (2,034) and represents the first major "stab" at reforming
- [Affordable Health Care for America Act: Implications for SNFs](https://rhislop3.com/affordable-health-care-for-america-act-implications-for-snfs/) - This weekend, the House is reportedly set to vote on their version of healthcare reform - H.R. 3962. The bill is a "monster"; nearly 2,000 pages long. The title belies the fact that the Bill doesn't just attempt to create "affordable health care" - it goes much, much further. For example, embedded within the hundreds of
- [CMS Releases Hospice Stats](https://rhislop3.com/cms-releases-hospice-stats/) - Within the past two weeks, CMS released data from 1998 to 2008 for length of stay and diagnosis trends. What is interesting to note is the utilization trends (length of stay and numbers) over the period as well as the diagnosis correlated to utilization. For CMS and in particular MedPAC, the prevailing concern has been
- [Healthcare Reform: Now the House Version](https://rhislop3.com/healthcare-reform-now-the-house-version/) - Earlier today, Speaker Pelosi introduced the re-tooled House version of healthcare reform, now titled The Affordable Health Care Act. The 2,000 page bill is the result of weeks of backroom negotiations designed to forge a possible consensus, principally among Democrats, and to financially wrangle, a targeted budget neutral spending level. According to Pelosi, the Bill
- [Healthcare Reform Update: Inside Baseball Time](https://rhislop3.com/healthcare-reform-update-inside-baseball-time/) - If you are a baseball fan, you'll appreciate the correlation between a baseball game and the present course of healthcare reform. A baseball game starts with anticipation and fanfare; speeches, the throwing out of the first pitch, the national anthem and the players taking the field. The fans settle in and the game begins with cheers
- [CCRCs and Problems: Much Ado About Likely, Very Little](https://rhislop3.com/ccrcs-and-problems-much-ado-about-likely-very-little/) - A product that has seen its share of struggles in the economic downturn is entry-fee CCRCs. To clarify, not all CCRC models are struggling and not even all entry-fee based CCRCs are struggling as certain regions have seen less housing market fall-out and concurrently, operators have done the right things to keep their census stable during the "down
- [Getting Risks Under Control: Improving Organizational Prosperity](https://rhislop3.com/getting-risks-under-control-improving-organizational-prosperity/) - Healthcare is a risky business; particularly in heavily regulated environments such as nursing homes and home health and hospice. The fact that a certain level of risk is omnipresent means that the opportunity constantly exists for an organization that improperly identifies and manages its risks, to suffer expensive damages ranging from financial loss to loss
- [Credit Markets to Remain Tight: FDIC Issues Caution](https://rhislop3.com/credit-markets-to-remain-tight-fdic-issues-caution/) - The Chairman of the Federal Deposit Insurance Corporation issued a statement warning that the biggest area of remaining risk for banks is commercial real estate loans. Her statement comes as a result of continued rising losses on commercial real estate loan portfolios. To date, over the past two years, banks have written off $6.2 billion
- [OIG Reports Published on Hospice](https://rhislop3.com/oig-reports-published-on-hospice/) - In a post I wrote at the end of July concerning CMS' 2010 rate announcement and compliance and regulatory trends, I indicated how the OIG was becoming more vigilant in reviewing hospice utilization, lengths of stay and in particular, the correlation between lengths of stay and hospice patients in an SNF. This past month, in mid-September, the
- [Skilled Nursing Facilities, Healthcare Reform and Gloomy Propsects](https://rhislop3.com/skilled-nursing-facilities-healthcare-reform-and-gloomy-propsects/) - On October 1, the SNF industry received a 1.1% reduction in Medicare payments. On October 13th, the Senate Finance Committee passed its version of Healthcare Reform, commonly known as the Baucus Bill. While the Baucus Bill is the least penalizing to the industry, of the major health reform bills waiting in Congress, it is destined for the Senate shredder
- [Baucus Bill Survives Committee: What Next](https://rhislop3.com/baucus-bill-survives-committee-what-next/) - The Senate Finance Committee this afternoon, on a vote of 14-9, approved the Baucus Bill out of committee, sending it theoretically to a floor vote. Sen. Olympia Snowe, a Republican from Maine, was the lone Republican vote in support. The Bill, a center of recent controversy in terms of its lack of reported details, incomplete
- [Senate Reform Bill Budget Neutral?](https://rhislop3.com/senate-reform-bill-budget-neutral/) - This afternoon, the Congressional Budget Office released a statement saying that the Senate Finance Committee Reform Bill (the Baucus Bill) prices out at $829 billion over ten years. At this price-tag, given the revenue assumptions (fees, cuts, taxes, etc.) contained in the Bill, the CBO estimates that the Bill actually produces a modest deficit reduction
- [Healthcare Economic Outlook](https://rhislop3.com/healthcare-economic-outlook/) - As my work is focused on healthcare and more succinctly, post-acute healthcare and senior housing, I follow overall economic trends and conditions and translate the same for the healthcare economy. As healthcare remains a private industry today, albeit one that is heavily tied to the Federal government, the general economy does impact the healthcare industry. Arguably, as with the
- [Senate Health Reform Bill Loses Public Option](https://rhislop3.com/senate-health-reform-bill-loses-public-option/) - The Senate Finance Committee voted yesterday to eliminate the public option from its reform bill (aka the Baucus Bill) by a margin of 15 to 8. All Republicans and a hand-full of Democrats voted against inclusion. Of note, the Bill's author, Senator Baucus voted for the removal of the public option stating that in his
- [GAO on CRRCs and Boards of Directors](https://rhislop3.com/gao-on-crrcs-and-boards-of-directors/) - Earlier this year, Senator Kohl, Chair of the Senate Aging Committee, requested that the GAO study the finances, operations and governance of CCRCs. According to Kohl, seniors invest significant portions of their life savings when entering a CCRC and in many cases, little is known about CCRC operators and less is regulated in regard to
- [Reform: The Senate Version](https://rhislop3.com/reform-the-senate-version/) - After weeks/months of meetings, Senator Baucus of Montana representing the "gang of six" (three Democrats and three Republicans) released the Senate Finance Committee version of "healthcare reform". What started as a bi-partisan sub-committee alternative to the House version (HR 3200) ended as essentially, a Baucus bill; legislation lacking any real support from Senate Democrats and
- [Holding onto Your D.O.N.](https://rhislop3.com/holding-onto-your-d-o-n/) - In our annual Healthcare Leadership Labor Market Report released in July, we presented some rather alarming trends regarding the long-term care and post-acute care industry's retention of nursing executives. For example, we noted that 71% of the Directors of Nursing in nursing homes leave their positions each year. We also noted that the average tenure
- [Deficits and Health Care: Economics Redux](https://rhislop3.com/deficits-and-health-care-economics-redux/) - I know this is supposed to be a blog about healthcare issues, primarily that which falls in the post-acute, long-term care and senior housing world but some stuff in the news right now is just too hard to ignore. After all, healthcare reform does affect long-term care and post-acute care directly and economics, especially the
- [Translating "Washington" Speak](https://rhislop3.com/translating-washington-speak/) - Not unexpectedly, the politicians are all a "buzz" about healthcare reform right now. The President even did a live radio/television talk-show to "clarify" what healthcare reform is really about; to translate as it were. From CNN to Fox to certainly every Sunday talk show, politicians or members of the President's cabinet are trying desperately to
- [SNF Sales: Is the Market Back?](https://rhislop3.com/snf-sales-is-the-market-back/) - According to the most recent release of the Dealmakers Forum published by Irving Levin Associates, July witnessed a sizable increase in transaction volume across the long-term care sector. As I noted in my last post on Assisted Living and Senior Housing, we have begun to see some volume pick-up in these segments although modest in
- [Assisted Living/Senior Housing Update](https://rhislop3.com/assisted-livingsenior-housing-update/) - For the past nine months we've watched the cap rates trend up, occupancy trend down and the transaction market remain stagnant. The credit crisis of one year ago definitely chilled the "buyer" side and as a result, shoved values downward. The deals we did see done were few and far between, lots of one off
- [Will Reform Happen?](https://rhislop3.com/will-reform-happen/) - Recess - when I was a kid it was the best part of school. Recess was a period of task abandonment; a temporary reprieve from the classroom engagement and the pedagogy. Unfortunately for Congress, recess means a time to confront constituents and to engage on the home front. For members of the House facing early
- [Home Health Update](https://rhislop3.com/home-health-update/) - As is/was the case with SNFs and Hospices, CMS and Congress have formulated a series of proposed rules and legislation that reflects the ongoing trend under Medicare of reimbursement reductions. On July 30 (followed by the August 6th Federal Register publication), CMS announced its proposed rule for FY 2010 for Home Health PPS reimbursement and
- [SNF Update](https://rhislop3.com/snf-update/) - What looks like the beginning to a rough late-summer/early-fall period, there are now numerous pending and current policy and reimbursement events that are breaking in the SNF industry. From the July 31 CMS announcement regarding Medicare payment reductions to the release of the marked-up House Tri-Committee bill on Health Care Reform (HR 3200) on the
- [Hospice Update](https://rhislop3.com/hospice-update/) - In March, I wrote about the MedPAC recommendations to change the Medicare Hospice program and payment system. Yesterday, CMS announced the final (2010) payment for Hospice as well as the implementation structure of some key MedPAC recommendations. The final rule will be published August 6th in the Federal Register. For FY 2010 (commencing October 1),
- [Duties of Boards: An OIG Perspective](https://rhislop3.com/duties-of-boards-an-oig-perspective/) - This seemed to be a natural successor topic to my last post, "Why Quality Matters"; principally arising out of recent press releases from the OIG. For example, in June the OIG reported that it had recovered $2.4 Billion in fraud, waste and abuse. In July, an OIG release reported that a Nursing Home Executive was banned
- [Why Quality Matters](https://rhislop3.com/why-quality-matters/) - In the past month or so I have had a lot of conversations with various entities ranging from providers to investors about the financial state of the industry. The majority of the discussions have been around all things financial - reimbursement in particular and as this topic goes, so goes expenses. Understandably the economic and
- [Diversification: Staying on Top in a Changing Industry](https://rhislop3.com/diversification-staying-on-top-in-a-changing-industry/) - Without question, the post-acute healthcare industry is changing. Every sector, from skilled nursing to assisted living to senior housing to home health and hospice has and will continue to undergo, some form of transformation. The reasons are many ranging from federal health policy changes, reimbursement changes, regulatory changes, the economy in general and the real
- [Wisconsin's Newest Triple Tax](https://rhislop3.com/wisconsins-newest-triple-tax/) - Wisconsin's new budget creates significant new healthcare tax levels as a means of raising additional Federal matching dollars. This flawed economic approach will only serve to raise the costs of healthcare for every consumer in the state while not directly providing the reimbursement relief touted.
- [Ten SNF Industry Trends to Watch](https://rhislop3.com/ten-snf-industry-trends-to-watch/) - Ten SNF industry trends that will impact the industry financially and operationally in 2009 and 2010.
- [Senior Living vs. Senior Lifestyle: Adjusting the Development Curve](https://rhislop3.com/senior-living-vs-senior-lifestyle-adjusting-the-development-curve/) - Creating the right "next generation" environment requires a complete re-visioning of the convetional senior housing model. Incorporating new design elements within the space is not only mandatory in new environments but critical in existing environments as well. Most assuredly, lifesytle issues will bear far more weight on the success or failure of any new or existing project as the next generation of seniors migrate or downsize from their homes to a specialized environment.
- [Walking Away from the Ledge: A Different Perspective on Healthcare Reform](https://rhislop3.com/walking-away-from-the-ledge-a-different-perspective-on-healthcare-reform/) - On Monday I wrote about the abyss that is the current state of healthcare reform in Washington - the enormous black hole that the U.S. will certainly fall in if we as a nation, progress along the path chosen by Mr. Obama and his party. Succinctly put, the expense of Federalizing healthcare in the U.S. combined
- [The Federal Healthcare Abyss](https://rhislop3.com/the-federal-healthcare-abyss/) - Fresh off an oversea tour and a visit to France no less, the President returns promising to become more engaged and agressive in getting his healthcare plan passed; ideally says he, by this summer. The reasons Mr. Obama proffers are many and urgent. Chief among the reasons is that the system (healthcare) is broke (and
- [Creating the Right Niche'](https://rhislop3.com/creating-the-right-niche/) - With the economy the way it is and the real estate market not quite into "recovery" mode as of yet, many senior housing projects are struggling to find their footing and thus, achievedesired occupancy levels. This is particularly true of projects that have entry fees or endowments as part of their pricing or where monthly
- [Medicaid Shell Game - Part Two](https://rhislop3.com/medicaid-shell-game-part-two/) - A while back I wrote about the annual/bi-annual shell game that is perpetrated in Wisconsin with the Medicaid program - specifically, the SNF funding and reimbursement components thereto. Now that the Joint Finance Committee of the Legislature has completed its budget process, we can see, fully exposed, how much of the shell game has really
- [Continued Medicaid Shell Game](https://rhislop3.com/continued-medicaid-shell-game/) - Here we go again, another round of the bi-annual Medicaid shell game to theoretically increase Medicaid SNF rates in Wisconsin. If you aren't familiar with this trick, watch closely because the moving parts are designed to confuse you - hence the illusion. The trick starts with the State having a continuing budget deficit overall. Don't
- [Hospice MedPAC Wrap Up](https://rhislop3.com/hospice-medpac-wrap-up/) - Hospice Update – Spring 09 Overview Commencing with its June 2004 report to Congress, MedPAC (Medicare Payment Advisory Commission) has been trending a series of reform recommendations to the Medicare Hospice Benefit. The Hospice benefit remains essentially intact along with its payment system since its inception in 1983. Originating from a demonstration program

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- [Final Home](https://rhislop3.com/) - rhislop3 Reginald Hislop, III is a veteran healthcare executive with more than 40 years of senior leadership experience in healthcare, post-acute care, senior living, mergers and acquisitions, and hea…
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- [Reginald Hislop III – Healthcare Executive/Senior Living & Post-Acute Strategist/Author](https://rhislop3.com/author/) - rhislop3 Reginald Hislop, III is a veteran healthcare executive with more than 40 years of senior leadership experience in healthcare, post-acute care, senior living, mergers and acquisitions, and healthcare economics. He is the founder of H2 Healthcare LLC and the author of Reg’s Blog, where he publishes analytical commentary on the intersection of federal policy and
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## Categories

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- [class action suit](https://rhislop3.com/tag/class-action-suit/)
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- [Conference Board](https://rhislop3.com/tag/conference-board/)
- [Congratulations](https://rhislop3.com/tag/congratulations/)
- [congregate housing](https://rhislop3.com/tag/congregate-housing/)
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- [Consultant Pharmacists](https://rhislop3.com/tag/consultant-pharmacists/)
- [Consumer Confidence](https://rhislop3.com/tag/consumer-confidence/)
- [Consumer Sentiment](https://rhislop3.com/tag/consumer-sentiment/)
- [Consumption](https://rhislop3.com/tag/consumption/)
- [Continental Congress](https://rhislop3.com/tag/continental-congress/)
- [Continuous Care](https://rhislop3.com/tag/continuous-care/)
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- [contractors](https://rhislop3.com/tag/contractors/)
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- [cooking](https://rhislop3.com/tag/cooking/)
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- [Core CPI](https://rhislop3.com/tag/core-cpi/)
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- [corporate structure](https://rhislop3.com/tag/corporate-structure/)
- [Cost](https://rhislop3.com/tag/cost/)
- [Cost of Care](https://rhislop3.com/tag/cost-of-care/)
- [Cost of Care Survey 2023](https://rhislop3.com/tag/cost-of-care-survey-2023/)
- [cost of money](https://rhislop3.com/tag/cost-of-money/)
- [Cost Reports](https://rhislop3.com/tag/cost-reports/)
- [Costs](https://rhislop3.com/tag/costs/)
- [Court of Appeals](https://rhislop3.com/tag/court-of-appeals/)
- [Courts](https://rhislop3.com/tag/courts/)
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- [Coverage Criteria](https://rhislop3.com/tag/coverage-criteria/)
- [coverage decisions](https://rhislop3.com/tag/coverage-decisions/)
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- [COVID](https://rhislop3.com/tag/covid/)
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- [cybersecurity](https://rhislop3.com/tag/cybersecurity/)
- [D-Day](https://rhislop3.com/tag/d-day/)
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- [death rates](https://rhislop3.com/tag/death-rates/)
- [Debt](https://rhislop3.com/tag/debt/)
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- [Demand](https://rhislop3.com/tag/demand/)
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- [Department of Justice](https://rhislop3.com/tag/department-of-justice/)
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- [Depression](https://rhislop3.com/tag/depression/)
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- [economic conditions](https://rhislop3.com/tag/economic-conditions/)
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- [elasticity of demand](https://rhislop3.com/tag/elasticity-of-demand/)
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- [Energy](https://rhislop3.com/tag/energy/)
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- [enforcement](https://rhislop3.com/tag/enforcement/)
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- [Faith](https://rhislop3.com/tag/faith/)
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- [Feasibility](https://rhislop3.com/tag/feasibility/)
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- [Federal Law](https://rhislop3.com/tag/federal-law/)
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- [finance](https://rhislop3.com/tag/finance/)
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- [Financial Data](https://rhislop3.com/tag/financial-data/)
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- [Fiscal Cliff](https://rhislop3.com/tag/fiscal-cliff/)
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- [GDP](https://rhislop3.com/tag/gdp/)
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- [General Inpatient Care](https://rhislop3.com/tag/general-inpatient-care/)
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- [Governance](https://rhislop3.com/tag/governance/)
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- [grateful](https://rhislop3.com/tag/grateful/)
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- [Health Care Cybersecurity Improvement Act of 2024](https://rhislop3.com/tag/health-care-cybersecurity-improvement-act-of-2024/)
- [Health Care Development](https://rhislop3.com/tag/health-care-development/)
- [Health Care Reform](https://rhislop3.com/tag/health-care-reform/)
- [Health Care Task Force](https://rhislop3.com/tag/health-care-task-force/)
- [Health Insurance](https://rhislop3.com/tag/health-insurance/)
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- [Healthcare](https://rhislop3.com/tag/healthcare/)
- [Healthcare cost](https://rhislop3.com/tag/healthcare-cost/)
- [Healthcare Price Index](https://rhislop3.com/tag/healthcare-price-index/)
- [Healthcare Reform](https://rhislop3.com/tag/healthcare-reform/)
- [healthcare spending](https://rhislop3.com/tag/healthcare-spending/)
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- [HHCAHPS](https://rhislop3.com/tag/hhcahps/)
- [HHS](https://rhislop3.com/tag/hhs/)
- [hidden market](https://rhislop3.com/tag/hidden-market/)
- [Higher Acuity](https://rhislop3.com/tag/higher-acuity/)
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- [hiring](https://rhislop3.com/tag/hiring/)
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- [Holidays](https://rhislop3.com/tag/holidays/)
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- [Home Care](https://rhislop3.com/tag/home-care/)
- [Home Health](https://rhislop3.com/tag/home-health/)
- [Home Health Final Rule](https://rhislop3.com/tag/home-health-final-rule/)
- [Home Sales](https://rhislop3.com/tag/home-sales/)
- [Honor](https://rhislop3.com/tag/honor/)
- [HOPE](https://rhislop3.com/tag/hope/)
- [Hospice](https://rhislop3.com/tag/hospice/)
- [Hospice Final Rule](https://rhislop3.com/tag/hospice-final-rule/)
- [Hospital at Home](https://rhislop3.com/tag/hospital-at-home/)
- [hospitalists](https://rhislop3.com/tag/hospitalists/)
- [hospitalizations](https://rhislop3.com/tag/hospitalizations/)
- [Hospitals](https://rhislop3.com/tag/hospitals/)
- [Hours Per Day](https://rhislop3.com/tag/hours-per-day/)
- [Hours Per Resident Day](https://rhislop3.com/tag/hours-per-resident-day/)
- [House](https://rhislop3.com/tag/house/)
- [House Budget Committee](https://rhislop3.com/tag/house-budget-committee/)
- [Housekeeping](https://rhislop3.com/tag/housekeeping/)
- [housing](https://rhislop3.com/tag/housing/)
- [HQRP](https://rhislop3.com/tag/hqrp/)
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- [immunity](https://rhislop3.com/tag/immunity/)
- [IMPACT Act](https://rhislop3.com/tag/impact-act/)
- [Improvement](https://rhislop3.com/tag/improvement/)
- [income](https://rhislop3.com/tag/income/)
- [Increase in Cancers](https://rhislop3.com/tag/increase-in-cancers/)
- [incrementalism](https://rhislop3.com/tag/incrementalism/)
- [Independence Day](https://rhislop3.com/tag/independence-day/)
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- [Industry Outlook](https://rhislop3.com/tag/industry-outlook/)
- [infection control](https://rhislop3.com/tag/infection-control/)
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- [interim rule](https://rhislop3.com/tag/interim-rule/)
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- [job growth](https://rhislop3.com/tag/job-growth/)
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- [Life Plan Community](https://rhislop3.com/tag/life-plan-community/)
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- [Lifestyle Housing](https://rhislop3.com/tag/lifestyle-housing/)
- [LinkedIn](https://rhislop3.com/tag/linkedin/)
- [Linus](https://rhislop3.com/tag/linus/)
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- [Lombardo](https://rhislop3.com/tag/lombardo/)
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- [Long-term Care](https://rhislop3.com/tag/long-term-care/)
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- [MACPAC](https://rhislop3.com/tag/macpac/)
- [MACs](https://rhislop3.com/tag/macs/)
- [managed care](https://rhislop3.com/tag/managed-care/)
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- [management theory](https://rhislop3.com/tag/management-theory/)
- [mandates](https://rhislop3.com/tag/mandates/)
- [Manual](https://rhislop3.com/tag/manual/)
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- [margins](https://rhislop3.com/tag/margins/)
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- [Market Conditions](https://rhislop3.com/tag/market-conditions/)
- [Market Research](https://rhislop3.com/tag/market-research/)
- [Market Share](https://rhislop3.com/tag/market-share/)
- [Market Trends](https://rhislop3.com/tag/market-trends/)
- [Marketing](https://rhislop3.com/tag/marketing/)
- [Markets](https://rhislop3.com/tag/markets/)
- [masking](https://rhislop3.com/tag/masking/)
- [Massachusetts](https://rhislop3.com/tag/massachusetts/)
- [MDS](https://rhislop3.com/tag/mds/)
- [Meaning of Life](https://rhislop3.com/tag/meaning-of-life/)
- [meaningful use](https://rhislop3.com/tag/meaningful-use/)
- [Media](https://rhislop3.com/tag/media/)
- [Medians](https://rhislop3.com/tag/medians/)
- [Medicaid](https://rhislop3.com/tag/medicaid/)
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- [Medicaid Disproportionate Share Hospitals](https://rhislop3.com/tag/medicaid-disproportionate-share-hospitals/)
- [Medicaid Waiver](https://rhislop3.com/tag/medicaid-waiver/)
- [medical care](https://rhislop3.com/tag/medical-care/)
- [Medical Device](https://rhislop3.com/tag/medical-device/)
- [Medical Homes](https://rhislop3.com/tag/medical-homes/)
- [medical malpractice](https://rhislop3.com/tag/medical-malpractice/)
- [medical records](https://rhislop3.com/tag/medical-records/)
- [Medicare](https://rhislop3.com/tag/medicare/)
- [Medicare Accelerated Payment Program](https://rhislop3.com/tag/medicare-accelerated-payment-program/)
- [Medicare Advantage](https://rhislop3.com/tag/medicare-advantage/)
- [Medicare Benefits](https://rhislop3.com/tag/medicare-benefits/)
- [Medicare Dependent Hospitals](https://rhislop3.com/tag/medicare-dependent-hospitals/)
- [Medicare Physician Fee Schedule](https://rhislop3.com/tag/medicare-physician-fee-schedule/)
- [Medicare Solvency](https://rhislop3.com/tag/medicare-solvency/)
- [medications](https://rhislop3.com/tag/medications/)
- [MedPac](https://rhislop3.com/tag/medpac/)
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- [Mental Health](https://rhislop3.com/tag/mental-health/)
- [Mental Illness](https://rhislop3.com/tag/mental-illness/)
- [Mergers](https://rhislop3.com/tag/mergers/)
- [Merry Christmas](https://rhislop3.com/tag/merry-christmas/)
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- [Monetary Policy](https://rhislop3.com/tag/monetary-policy/)
- [Money](https://rhislop3.com/tag/money/)
- [monthly fees](https://rhislop3.com/tag/monthly-fees/)
- [Morningstar](https://rhislop3.com/tag/morningstar/)
- [mortgage](https://rhislop3.com/tag/mortgage/)
- [mortgage rates](https://rhislop3.com/tag/mortgage-rates/)
- [Mother's Day](https://rhislop3.com/tag/mothers-day/)
- [Movies](https://rhislop3.com/tag/movies/)
- [multidisciplinary](https://rhislop3.com/tag/multidisciplinary/)
- [NAR](https://rhislop3.com/tag/nar/)
- [National Association of ACOs](https://rhislop3.com/tag/national-association-of-acos/)
- [National Association of Realtors](https://rhislop3.com/tag/national-association-of-realtors/)
- [National Council on Assisted Living](https://rhislop3.com/tag/national-council-on-assisted-living/)
- [National Fire and Marine](https://rhislop3.com/tag/national-fire-and-marine/)
- [National Investment Center](https://rhislop3.com/tag/national-investment-center/)
- [National Mental Health Day](https://rhislop3.com/tag/national-mental-health-day/)
- [National Signing Day](https://rhislop3.com/tag/national-signing-day/)
- [Navy](https://rhislop3.com/tag/navy/)
- [NBER](https://rhislop3.com/tag/nber/)
- [NCAL](https://rhislop3.com/tag/ncal/)
- [Negligence](https://rhislop3.com/tag/negligence/)
- [neoplasms](https://rhislop3.com/tag/neoplasms/)
- [network](https://rhislop3.com/tag/network/)
- [New Construction](https://rhislop3.com/tag/new-construction/)
- [New Jobs](https://rhislop3.com/tag/new-jobs/)
- [New York](https://rhislop3.com/tag/new-york/)
- [New York Times](https://rhislop3.com/tag/new-york-times/)
- [news](https://rhislop3.com/tag/news/)
- [NHAs](https://rhislop3.com/tag/nhas/)
- [NIC](https://rhislop3.com/tag/nic/)
- [Non-Compete](https://rhislop3.com/tag/non-compete/)
- [Non-Profit](https://rhislop3.com/tag/non-profit/)
- [NORC](https://rhislop3.com/tag/norc/)
- [Norman Vincent Peale](https://rhislop3.com/tag/norman-vincent-peale/)
- [Nostalgia](https://rhislop3.com/tag/nostalgia/)
- [November 11](https://rhislop3.com/tag/november-11/)
- [Nursa](https://rhislop3.com/tag/nursa/)
- [Nurses](https://rhislop3.com/tag/nurses/)
- [Nursing](https://rhislop3.com/tag/nursing/)
- [Nursing Care](https://rhislop3.com/tag/nursing-care/)
- [Nursing Facilities](https://rhislop3.com/tag/nursing-facilities/)
- [Nursing Home](https://rhislop3.com/tag/nursing-home/)
- [Nursing Home Closures](https://rhislop3.com/tag/nursing-home-closures/)
- [Nursing Homes](https://rhislop3.com/tag/nursing-homes/)
- [Nursing schools](https://rhislop3.com/tag/nursing-schools/)
- [nursing staff](https://rhislop3.com/tag/nursing-staff/)
- [Obamacare](https://rhislop3.com/tag/obamacare/)
- [Obamacare. Trump](https://rhislop3.com/tag/obamacare-trump/)
- [Observation Stays](https://rhislop3.com/tag/observation-stays/)
- [Occam's Razor](https://rhislop3.com/tag/occams-razor/)
- [Occupancy](https://rhislop3.com/tag/occupancy/)
- [Occupancy Trends](https://rhislop3.com/tag/occupancy-trends/)
- [OCR](https://rhislop3.com/tag/ocr/)
- [Odyssey](https://rhislop3.com/tag/odyssey/)
- [Office of Actuary](https://rhislop3.com/tag/office-of-actuary/)
- [OIG](https://rhislop3.com/tag/oig/)
- [Old Glory](https://rhislop3.com/tag/old-glory/)
- [Older Adults](https://rhislop3.com/tag/older-adults/)
- [OMB](https://rhislop3.com/tag/omb/)
- [omnibus](https://rhislop3.com/tag/omnibus/)
- [one-year nursing program](https://rhislop3.com/tag/one-year-nursing-program/)
- [Opportunities. Census](https://rhislop3.com/tag/opportunities-census/)
- [Outlook](https://rhislop3.com/tag/outlook/)
- [Outpatient](https://rhislop3.com/tag/outpatient/)
- [Oversight](https://rhislop3.com/tag/oversight/)
- [Owner's Rep](https://rhislop3.com/tag/owners-rep/)
- [Ownership](https://rhislop3.com/tag/ownership/)
- [Ownership Disclosure](https://rhislop3.com/tag/ownership-disclosure/)
- [ownership. outcomes](https://rhislop3.com/tag/ownership-outcomes/)
- [Oxford Valley Health](https://rhislop3.com/tag/oxford-valley-health/)
- [PACE](https://rhislop3.com/tag/pace/)
- [pandemic](https://rhislop3.com/tag/pandemic/)
- [Part A](https://rhislop3.com/tag/part-a/)
- [Part B](https://rhislop3.com/tag/part-b/)
- [Part C](https://rhislop3.com/tag/part-c/)
- [Part D](https://rhislop3.com/tag/part-d/)
- [Pastoral Care](https://rhislop3.com/tag/pastoral-care/)
- [Pathways](https://rhislop3.com/tag/pathways/)
- [Patient Care](https://rhislop3.com/tag/patient-care/)
- [patient experience](https://rhislop3.com/tag/patient-experience/)
- [patient outcomes](https://rhislop3.com/tag/patient-outcomes/)
- [Patriotism](https://rhislop3.com/tag/patriotism/)
- [Payer Mix. Medicare](https://rhislop3.com/tag/payer-mix-medicare/)
- [Payment](https://rhislop3.com/tag/payment/)
- [payments](https://rhislop3.com/tag/payments/)
- [PBJ](https://rhislop3.com/tag/pbj/)
- [PBS](https://rhislop3.com/tag/pbs/)
- [PCE](https://rhislop3.com/tag/pce/)
- [PDGM](https://rhislop3.com/tag/pdgm/)
- [PDPM](https://rhislop3.com/tag/pdpm/)
- [Peace](https://rhislop3.com/tag/peace/)
- [Peanuts](https://rhislop3.com/tag/peanuts/)
- [Pelosi](https://rhislop3.com/tag/pelosi/)
- [penalties](https://rhislop3.com/tag/penalties/)
- [penitence](https://rhislop3.com/tag/penitence/)
- [Penn and Teller](https://rhislop3.com/tag/penn-and-teller/)
- [Penn Wharton](https://rhislop3.com/tag/penn-wharton/)
- [Pentagon](https://rhislop3.com/tag/pentagon/)
- [Performance](https://rhislop3.com/tag/performance/)
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- [Personal Development](https://rhislop3.com/tag/personal-development/)
- [Personal health spending](https://rhislop3.com/tag/personal-health-spending/)
- [personal representative](https://rhislop3.com/tag/personal-representative/)
- [Petersen Health Care](https://rhislop3.com/tag/petersen-health-care/)
- [Pharmacy](https://rhislop3.com/tag/pharmacy/)
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- [PHE waivers](https://rhislop3.com/tag/phe-waivers/)
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- [Physician Fee Schedule](https://rhislop3.com/tag/physician-fee-schedule/)
- [Physician Fees](https://rhislop3.com/tag/physician-fees/)
- [physician spending](https://rhislop3.com/tag/physician-spending/)
- [Physicians](https://rhislop3.com/tag/physicians/)
- [pie](https://rhislop3.com/tag/pie/)
- [Planning](https://rhislop3.com/tag/planning/)
- [Plans](https://rhislop3.com/tag/plans/)
- [POA](https://rhislop3.com/tag/poa/)
- [Polansky decisions](https://rhislop3.com/tag/polansky-decisions/)
- [Policy](https://rhislop3.com/tag/policy/)
- [Politics](https://rhislop3.com/tag/politics/)
- [poly-pharmacy](https://rhislop3.com/tag/poly-pharmacy/)
- [poor care](https://rhislop3.com/tag/poor-care/)
- [population](https://rhislop3.com/tag/population/)
- [Positivity](https://rhislop3.com/tag/positivity/)
- [Post-Acute](https://rhislop3.com/tag/post-acute/)
- [post-acute care](https://rhislop3.com/tag/post-acute-care/)
- [potatoes](https://rhislop3.com/tag/potatoes/)
- [Power of Positive Thinking](https://rhislop3.com/tag/power-of-positive-thinking/)
- [Power Point](https://rhislop3.com/tag/power-point/)
- [PPACA](https://rhislop3.com/tag/ppaca/)
- [PPI](https://rhislop3.com/tag/ppi/)
- [PPS](https://rhislop3.com/tag/pps/)
- [PPS. PDGM](https://rhislop3.com/tag/pps-pdgm/)
- [Practice Management](https://rhislop3.com/tag/practice-management/)
- [Pray for Peace](https://rhislop3.com/tag/pray-for-peace/)
- [PRC National Nursing Engagement Report](https://rhislop3.com/tag/prc-national-nursing-engagement-report/)
- [pre-pandemic](https://rhislop3.com/tag/pre-pandemic/)
- [PREP Act](https://rhislop3.com/tag/prep-act/)
- [Prescription Drug Costs](https://rhislop3.com/tag/prescription-drug-costs/)
- [Presentation](https://rhislop3.com/tag/presentation/)
- [presentations](https://rhislop3.com/tag/presentations/)
- [Preserving Access](https://rhislop3.com/tag/preserving-access/)
- [President](https://rhislop3.com/tag/president/)
- [President Biden's Budget](https://rhislop3.com/tag/president-bidens-budget/)
- [President's Budget Proposal](https://rhislop3.com/tag/presidents-budget-proposal/)
- [Presidential](https://rhislop3.com/tag/presidential/)
- [price](https://rhislop3.com/tag/price/)
- [price setting](https://rhislop3.com/tag/price-setting/)
- [Price Waterhouse Coopers](https://rhislop3.com/tag/price-waterhouse-coopers/)
- [prices](https://rhislop3.com/tag/prices/)
- [Pricing](https://rhislop3.com/tag/pricing/)
- [Primary Care](https://rhislop3.com/tag/primary-care/)
- [Prior Authorization](https://rhislop3.com/tag/prior-authorization/)
- [Private Equity](https://rhislop3.com/tag/private-equity/)
- [private insurance](https://rhislop3.com/tag/private-insurance/)
- [program](https://rhislop3.com/tag/program/)
- [program costs](https://rhislop3.com/tag/program-costs/)
- [programs of nursing](https://rhislop3.com/tag/programs-of-nursing/)
- [Project Management](https://rhislop3.com/tag/project-management/)
- [Property](https://rhislop3.com/tag/property/)
- [Property Tax](https://rhislop3.com/tag/property-tax/)
- [Proposed Rule](https://rhislop3.com/tag/proposed-rule/)
- [Proposed Rule 2025](https://rhislop3.com/tag/proposed-rule-2025/)
- [Provider Immunity](https://rhislop3.com/tag/provider-immunity/)
- [providers](https://rhislop3.com/tag/providers/)
- [public health](https://rhislop3.com/tag/public-health/)
- [public health emergency](https://rhislop3.com/tag/public-health-emergency/)
- [Pumpkin](https://rhislop3.com/tag/pumpkin/)
- [Pumpkins](https://rhislop3.com/tag/pumpkins/)
- [Purpose](https://rhislop3.com/tag/purpose/)
- [Q&A](https://rhislop3.com/tag/qa/)
- [QAPI](https://rhislop3.com/tag/qapi/)
- [QI/QA](https://rhislop3.com/tag/qi-qa/)
- [QM](https://rhislop3.com/tag/qm/)
- [QRP](https://rhislop3.com/tag/qrp/)
- [Quality](https://rhislop3.com/tag/quality/)
- [Quality Measures](https://rhislop3.com/tag/quality-measures/)
- [Quality Reporting](https://rhislop3.com/tag/quality-reporting/)
- [RAC](https://rhislop3.com/tag/rac/)
- [RACs](https://rhislop3.com/tag/racs/)
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