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 … Read more

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 … Read more

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 … Read more

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, … Read more

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 … Read more

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 … Read more

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 … Read more

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 … Read more

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 … Read more

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.  … Read more