Reg's Blog

Senior and Post-Acute Healthcare News and Topics

Reports and Other Documents

new-cop-for-snfs-phase-1

upcoming-post-acute-regulatory-issues-9-16

implementation-timeframes

CMS SNF Reform proposal

Entry Fee Pricing Worksheet

Pricing Worksheet (Leading Age Nashville presentation spreadsheet)

Intersection of Pricing and Marketing  (Leading Age Nashville presentation 10/14)

QAPI in ActionOhio {Leading Age Ohio Annual Conference 8/2014}

Data Driven Marketing Strategy full  (Leading Age 2013 annual conference presentation in Dallas)

QAPI in Action (Presentation)

Value Propositions and Markteting 10 23 12  (Presentation at Leading Age annual conference in Denver)

Strategic Pricing Strategies for Senior Housing

Report_on_Web_Based_Chronic_Disease_Management

Mar11_EntireReport  (MedPac 2011 Report)

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11 Comments »

  1. I found your article very interesting regarding nursing homes contracting with just one hospice agency for hospice services. I wholeheartedly agree! Do you have references in the Medicare Hospice Regulations that you would share with me? We are working with a nursing home now regarding this issue.

    Thank you!
    Steve Faulk
    Director
    Infirmary Hospice Care, Inc.

    Comment by Steve Faulk | December 29, 2010 | Reply

  2. I also would be very intrested in any references in the Medicare Hospice Regulations regarding nursing homes contracting with just one hospice agency for hospice services. Seems to be very popular with Nursing Homes owning their own hospice.

    Comment by Bryan | February 5, 2011 | Reply

    • I think the regulation that deals with the idea of more than one hospice agency being available has to do with the requirement that all patients have informed consent to treatment and all options, etc. Under the informed consent requirement, a nursing home would be required to advise the patient that “these are the hospice agencies” available in this area. Most don’t do that and nobody is enforcing this regulation for the most part, so vertically-integrated systems can assign their own hospice to the patient and keep it all within the system, maximizing their revenue.

      I don’t think there is a specific regulation that states in clear language, “the nursing home must allow any hospice in to serve the patient.” It is implied under informed consent, patient rights to determine their own treatment, etc.

      The other thing that’s happening is illegal kickbacks to assure referral to a particular hospice, as the OIG has repeatedly warned about.

      Comment by Ron Panzer | July 28, 2011 | Reply

      • Mr. Panzer:

        As of current, there exists no requirement that an SNF must provide any resident with hospice resources in any fashion. The SNF may elect to not provide hospice via contract, to its residents and some do exactly that. The SNF alternatively may elect to contract with only one hospice organization and many do that. In fact, I’ve seen some that permit or execute contracts with any hospice organization based on resident request. Personally, I have always counseled my SNF clients to contract with one agency or two at most, simply to assure that staff are intimately familiar with the contract requirements, the hospice staff, and to develop exceptional processes that assure good care and compliance. Clearly, and the message has been implied by the OIG and MedPac consistently, modernization is needed in the Medicare Hospice benefit and in turn, the regulations.

        Thanks for the comment!

        Comment by Reg Hislop III | July 29, 2011

      • Hi Reg,

        In response to your reply to the above of JUly 29, 2011, you say there is no requirement that SNFs provide hospice services, however the federal regulations give Medicare eligible patients the right to access hospice services, so if they request it, an arrangement must be made for hospice services. This does not mean the SNF is providing any resources, but that a licensed, Medicare-certified hospice be allowed to provide those services. A SNF that prevents a patient from accessing the federal Medicare hospice benefit would be out of compliance with federal regulations.

        Comment by Ron Panzer | July 29, 2011

      • Mr. Panzer:
        Residents in an SNF have a right to access any Medicare service however, a SNF is under no obligation to provide the same to residents via contract or other. You will not find any language in the Federal Conditions of Participation for SNFs that require SNFs to provide any services, separate from those specified in the code. Hospice and SNF are two totally separately licensed and defined, levels of care. The only language the exists pertaining to SNFs and Hospice is where an SNF “chooses” to provide via contract, Hospice services to its residents. The code then specifices what must be in the contract between the two entities and the duties of each in terms of care services provided. You can view my related post on this site titled, “Hospice Reminders for SNFs” that covers the contractual and relationship requirements between SNFs and Hospices under current federal code.

        As of today, there remains no requirement for an SNF to enter into a contract with a hospice or to provide or cause to be provided, hospice services to its residents. An SNF is required, if a resident so chooses to enter a home or inpatient program, to appropriately discharge plan and assist with the coordination of benefits and other services as applicable to the discharge. This is the same requirement for SNFs however, concerning all discharges.

        Comment by Reg Hislop III | July 29, 2011

  3. Can you please provide me examples of CCRC value propositions? In particular, I am working on our value proposition for independent living accommodations. I am trying work through how we can make our independent living accommodations unique because there are other high quality CCRC’s in our local market. Thanks for your assistance.

    Comment by Rick Rusthoven | May 26, 2011 | Reply

    • Mr. Rusthoven:

      Thanks for reading and commenting. I suggest you follow the outline steps in the article on this site titled, “Economic Value Analysis, Value Propositions and Marketing”. I don’t have any specific sample works I can share that are not client related work-product and each is unique to its market area and the organization.

      Comment by Reg Hislop III | June 2, 2011 | Reply

  4. Are there Medicare Regulations that limit or restrict Nursing Home organizations in owning hospices?

    Comment by Philip Sorley | October 6, 2011 | Reply

    • Mr. Sorley:

      No, there are no regulations that prohibit ownership among different certified providers. In fact, many structures include different Medicare providers controlled by the same entity combining nursing homes, home health, hospice, etc. under one common entity. An organization that I headed as a CEO included nursing homes and hospices (among other provider entites such as physician groups) under a common parent entity. It is important to note however that ownership does not negate or immunize an organization from any federal laws that prohibit self-referral or require disclosure, not to mention any other administrative or federal code requirements. For example, in the case of a nursing home organization owning and operating a hospice, the nursing home can establish a contractual arrangement with its own hospice to provide hospice care to its residents. In fact, nothing today in current law prohibits the nursing home from having an “exclusive” contract with its own hospice. The key here is that the contract between the parties must conform to the provisions in the applicable medicare/federal regs as applied to each organization. Similarly, the two entities would have to be mindful of staffing arrangements such that the hospice had its own core staff as required and that the same staff were not de facto shared between the individual entities. Hospice requires core staff in nursing, social work, bereavement, and physician/medical director. Shared staff via contract, which can be with the nursing home, can include therapies, food service, activities, pharmacy, and others as may be required by patient need. The important point to remember is that while ownership may be common or shared, the operations of both entities are separate as far as the law is concerned and the resulting requirements for each provider (SNF and Hospice) are truly different and cannot be circumvented simply by common ownership. There are definite economies of scale that can come into play, provided that the “owning” organization is aware of the applciable federal regulations and uses proper structural steps to insure, where required, arms-length arrangements.

      Hope this helps and thanks for the comment.

      Comment by Reg Hislop III | October 6, 2011 | Reply

  5. We’re a group of volunteers and starting a new scheme in our community.
    Your web site offered us with valuable info to work on.
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    Comment by dallas tx hospice | October 4, 2013 | Reply


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