Accountable Care Organizations: A Post-Acute Perspective

Suffice to say, I am behind in getting this post “out”.  My best intentions of a month or so ago were quickly dashed by other more pressing commitments. Nonetheless, I did read the proposed regulations as produced by the Department of Health and Human Services/CMS on April 7 and worked through a stack of research on the subject of Accountable … Read more

Compliance, the Courts and a Risk Reminder

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

Health Reform Implications for Institutional Providers

My last post covered CMS’ proposed rule affecting LTAcHs in fiscal year 2011 (October 1, 2010).  In this post I noted that CMS’ proposed rule included a disclaimer that  any impacts related to the PPACA (health reform) were not included and as a result, CMS would from time to time, release updates providing additional guidance.  … Read more

Stark, Health Care Reform and Updated Compliance Requirements

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

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

Hospital Observation Stays Impacting Medicare SNF Admissions

An issue that I am fielding a fair number of inquiries about lately involves Medicare patients spending more than three days in a hospital, subsequently ‘discharged’ to a SNF and the SNF learning later that the patient was never technically admitted to the hospital.  Mostly, the inquiries I am getting are along the line of “what’s … Read more

Non-Profit Health Care Outlook for 2010

Moody’s Investor Service released their annual sector outlook today for not-for-profit health care organizations, stating that they (Moody’s) continue to maintain a “negative” outlook on the industry.  Important to note in this report is that the focus is principally on hospitals and since the report is produced by Moody’s, its primary perspective is on credit … Read more