Interoperability and Post-Acute Implications

I’m not sure how many of my readers are following the subject and CMS stance/policy on interoperability among providers but the concepts and resultant debate are rather interesting.  I am trying to encourage as many clients and readers to tune-in on this subject as the implications are sweeping – positively and negatively. Interoperability in this … Read more

SNFs and PBJ Article

Attached is a link a to a good PBJ (payroll based journal) article.  It covers the basic concepts of what is going on today with regard to staffing level reporting and the Five Star system.  Recall, staffing as a domain, is one of the stars in this system.  The article is posted here (re-published) with permission of … Read more

CMS Proposes Reintroduction of Pre-Payment Review for Home Health (with a twist)

In a memo set for release today, CMS is proposing to reintroduce pre-payment review (with a twist) for Home Health claims.  The memo version is here: HHA Pre Payment Recall, CMS first introduced pre-payment review in August 2016, starting in Illinois.  The process required agencies to submit claim-related data BEFORE receiving final payment or face an … Read more

CMS Proposes New SNF Payment Model

Last Friday, CMS released the contents of its annual proposed rule updating the SNF PPS plus (as always), fine tuning certain related programmatic elements. Final Federal Register Publication is set for May 8.  (Anyone wishing the PDF version may download it from the Reports and Other Documents page on this site or access it here … Read more

New Compliance/Survey Resource for SNFs

It is rare that I push or endorse any product on this site.  This is an exception worth making. http://hcmarketplace.com/survey-success-for-long-term-care The book is authored by my wife who also heads the Clinical Compliance practice within H2 Healthcare, LLC – the firm that I head.  She is our Senior Partner as well as the firm’s Chief … Read more

Hospice, Hospital Readmissions and Penalty Implications

Late yesterday, a reader (who also happens to be a client from time to time), posed this question to me. “When hospitals discharge to hospice and if the hospice has to readmit to the hospital, the hospital doesn’t get penalized for the readmit?  Is this true?”  Since this question is not one that I have … Read more

IMPACT Act, VBP, Care Coordination and the SNF Landscape

Now into February, its time to take stock of the Post-Acute/SNF landscape, particularly as the same pertains to the evolutionary policy initiatives in-play and moving forward.  To start, there is little evidence on the horizon of an all-out retreat on the policy changes begat by the ACA.  While some framework is building to “Repeal and Replace” … Read more

SNF M&A: The Provider Number Trap

Over my career, I have done a fair amount of M&A work….CCRCs, SNFs, HHAs, Physician practices, hospice, etc. While each “deal” has lots of nuances, issues, etc. none can be as confusing or as tricky to navigate as the federal payer issues; specifically, the provider number.  For SNFs, HHAs, and hospices, an acquisition not properly … Read more

Post Acute Resolutions for 2017

With a new year upon us and (perhaps) the most amount of free-flowing health policy changes happening or about to happen in decades, it seems appropriate to create some simple resolutions for the year ahead.  Similar to the personal resolutions most people make (get healthy, lose weight, clean closets, etc.), the following are about “improvements” … Read more

The Election is Over….Now What?

We knew that sooner or later, the first Tuesday in November would arrive and with that, a new President and changes (many or few) to Congress. The outcome certain, we move to uncertainty again concerning “what next”?…or as applicable here, what next from a health policy perspective. With Donald Trump the incoming President-Elect, only so … Read more