Friday Feature: Home Health Proposed Rule Implications

Last month, CMS dropped the 2024 PPS Proposed Rule for Home Health. Like all other provider segments, Proposed Rules function to address primarily payment, then other programmatic issues/rules such as quality measures, data reporting, etc. The proposals generally mirror the final rules, but tweaks do occur. The payment end, however, rarely changes much as often, … Read more

Staffing Level Mandate – Update

In this year’s final rule (PPS) for SNFs, CMS indicated that it would delineate proposals for final rule making this spring regarding mandated staffing levels. In the 2023 Final Rule, CMS solicited comment regarding staffing level mandates. In yesterday’s post on labor and job data, I covered how incomplete the staffing picture remained for senior … Read more

Hospice Alert: Regulatory Changes Likely, Soon

In a series of news stories starting with a piece in the New Yorker published last November, hospices, particularly for-profit hospices in certain states, are being called-out for fraudulent activity.  The New Yorker article headline begins, “It began as a visionary notion—that patients could die with dignity at home. Now it’s a twenty-two-billion-dollar industry plagued … Read more

Friday Feature: MedPAC, Single Payment, and the IMPACT Act

The Medicare Payment Advisory Commission (MedPAC) via a report submitted to Congress on Thursday (yesterday) indicated that a single post-acute payment under Medicare is feasible but extensive policy procedural changes would be required to make it workable. The concept is that one uniform payment would apply to post-acute care delivered in home health, skilled nursing, … Read more

OIG Initiatives for SNFs

On the heels of a report released in January of this year, the Office of Inspector General for the Department of Health and Human Services has created a series of regulatory reviews/quality initiatives for SNFs. The report focuses on the SNF experience during COVID and what, in the opinion of the OIG analysts, regulatory interventions … Read more

Supreme Court Decides: Nursing Home Residents/Families Can Sue Public Facilities

This morning, the Supreme Court ruled that residents and their surviving heirs/family members can sue a publicly owned nursing home under the Federal Nursing Home Reform Act. The court upheld a lower court ruling against the Health and Hospital Corporation of Marion County (HHC). This organization operates publicly owned (governmental) SNFs in Indiana. A couple … 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

May 11 and PHE: Provider Alert

On May 11, the COVID Public Health Emergency (PHE) is set to end and along with it, a whole slew of requirements end or change, and regulatory waivers applicable to the Public Health Emergency, the same (ending). The end of the PHE will have positive and negative impacts on providers of all types though some … Read more

Medicare Advantage/Part D Final Rule

Early in April, CMS released the 2024 Medicare Advantage/Part D Final Rule and within, there are a number of interesting policy shifts that could benefit providers. The rule addresses a common practice that has been frankly, often abused by Med Advantage plans – prior authorizations or more commonly known as, “prior auths”. The crux is … Read more

SNFs: 3 Overnight Stay Requirement Returning

As the Public Health Emergency (COVID) ends, healthcare providers will revisit pre-pandemic policies as a slew of waivers expire. One waiver particularly impactful to hospitals and SNFs is the requirement of a 3 Overnight (3 Day Stay) for a patient to receive Part A Medicare benefits in a SNF. Recall, the rule pre-pandemic was that … Read more