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. When employees feel empowered to speak up, they are more inclined to report issues related to safety, care, and to contribute service improvement suggestions, among other things. My firm, H2 Healthcare, has a robust compliance practice. … Read more

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, … Read more

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 … Read more

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 … Read more

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 … Read more

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 … Read more

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 … Read more

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 … Read more