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

Health Care Reform Implications: SNFs

The following is a summary of the major provisions in the recently passed health care reform bill.  Please note: I have not attempted to cover every nuance in detail but to provide a highlight for a point of reference.  If any reader has additional questions or wants additional insight on any particular provision, please let … Read more

Strategies for Accomplishing New Development or Major Capital Projects

One of the focal areas of my consulting practice/work is assisting health care organizations in accessing sources of funding (securing financing basically) for major projects and/or new development.  Given the state of the economy, most specifically the capital markets over the past eighteen months, getting funding for capital projects and/or development has been challenging, though … Read more

Medpac Report to Congress: 2011

Earlier this week, Medpac (Medicare Payment and Advisory Commission) released its report to Congress.  Primary among Medpac’s duties is its provision of recommendations regarding payment updates under Medicare.  Below, I have broken out and summarized the recommendations. Hospice (the points below the first bullet are continued recommendations from 2009) 2011 rate is the market-basket less a … 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

New HIPAA Provision Now in Effect

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

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

Sharpen the Sales and Marketing Efforts in 2010

I lost track this past year of how many people I talked to that told me that, “organizationally, we are kind of stalled in developing new business because of the economy and health care reform”.  I know that in down economic periods, promotion budgets (advertising, sponsorships,etc.) are some of the first line items trimmed but … Read more

Better Productivity, Better Retention: Labor Strategy for 2010

For the vast majority of providers, productivity and retention are ongoing labor hassles.  Salaries and benefits are typically, the single largest expense item for health care providers and when analyzed by all of the components, a surprising percentage is allocated for labor related expenses that can and should be, reduced.  Expenses such as Worker’s Compensation, recruitment, turnover, … Read more

Affordable Health Care for America Act: Implications for SNFs

This weekend, the House is reportedly set to vote on their version of healthcare reform – H.R. 3962.  The bill is a “monster”; nearly 2,000 pages long.  The title belies the fact that the Bill doesn’t just attempt to create “affordable health care” – it goes much, much further.  For example, embedded within the hundreds of … Read more