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 … Read more

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 … 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

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 … 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

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 … Read more

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 … Read more

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 … Read more

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 … Read more

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 … Read more