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 … Read more

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 … Read more

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 … Read more

QAPI: What’s 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, … Read more

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 … Read more

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 … Read more

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 … Read more

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 … Read more

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 … Read more

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 … Read more