Compliance

RUGs III to RUGs IV: The Core of “Need to Know”

by

In the past month with October 1 looming closer, I’ve been fielding lots of questions regarding the transition from RUGs III to RUGs IV.  Instead of listing the questions and trying to recap my answers (my memory is good but not that good), I’ve settled on an overview or “summary”; the core of what SNFs … Read more

Due Diligence and Acquisitions: A Review of Common Pitfalls

by

A regular, although not necessarily routine, exercise that I go through is a re-evaluation of recent acquisitions in the senior housing/long-term care industry to see “how they are doing or performing” post transaction.  Perhaps the primary reason that I do this is my curiosity regarding the effectiveness of the due diligence process and the accuracy … Read more

Compliance, the Courts and a Risk Reminder

by

In previous posts I’ve written about the need for providers in all industry sectors to fully understand the compliance and legal risks that are inherent to the appropriate industry sector, as well as to health care today in general.  As someone who has been immersed in health care operations and health policy for the past … Read more

As the Home Health and Hospice World Turns: Part I

by

Sorry for borrowing (piece of)  a soap opera title for this post but it is rather appropriate given the news that occurred over the past 30 days.  Just this past week, I’ve been interviewed by two business newspapers and on the phone with an investment banking firm I consult with from time to time regarding … Read more

Five Things Every Administrator Should Focus On

by

I had a phone conversation earlier today with a friend and colleague (he’s part owner of a rehab consulting and management company) and as we talked, the conversation reminded me about the host of issues facing health care administrators.  Our conversation flowed to long-term care and specifically, SNFs (he spends a lot of his time … Read more

Stark, Health Care Reform and Updated Compliance Requirements

by

When the Patient Protection and Affordable Care Act (PPACA) became law, a provision within adds a new dimension to the rules on self-referral and refund requirements of overpayment (Medicare) contained within the Stark Law.  Specifically, the PPACA requires the Secretary of HHS to develop a new self-disclosure protocol whereby health care providers can disclose known (or found) … Read more

Hospital Re-Admissions: Update to an Earlier Post

by

Last week I wrote about hospitals using “observation stays” as a means of dealing with the potential risk of reimbursement penalties imposed by CMS for certain re-admissions.  The focus of my post was on how the trend of hospitals using observation stays to avoid CMS scrutiny (and penalties) was impacting Medicare admissions at SNFs.  I … Read more

New HIPAA Provision Now in Effect

by

In August of 2009, the Department of Health and Human Services issued an interim final rule requiring that all HIPAA covered entities and their business associates develop notification requirements for a breach of unsecured protected health information (PHI).  These new requirements are part of the Health Information Technology for Economic and Clinical Health Act (HITECH).  In … Read more

Hospice Contract Reminders for SNFs

by

On a fairly routine basis, I run across SNF Administrators and Directors of Nursing that continue to have issues with hospice patients in their facilities but not from the standpoint of the patient typically; from the standpoint of dealing with the Hospice and the terms of the contract between the Hospice and the SNF.  In … Read more

OIG Reports Published on Hospice

by

In a post I wrote at the end of July concerning CMS’ 2010 rate announcement and compliance and regulatory trends, I indicated how the OIG was becoming more vigilant in reviewing hospice utilization, lengths of stay and in particular, the correlation between lengths of stay and hospice patients in an SNF.  This past month, in mid-September, the … Read more