OIG: CMS Should Take Action Against States with Poor SNF Survey Performance

Last week, the U.S. Department of Health and Human Services Office of the Inspector General (OIG), issued a report regarding the performance of contracted state agencies with respect to nursing home (SNF) compliance surveys. CMS contracts with state agencies, typically state departments of health or divisions thereto, to perform compliance/regulatory activities (surveys) in nursing homes. The report … Read more

OIG Issues Report on SNF Emergency Preparedness

Since the COVID pandemic, regulatory officials have escalated the review, via various audits, of SNF emergency preparedness. COVID highlighted the sporadic and often, non-existent preparations for disasters (natural and other) and disease outbreaks (pandemic or other) that existed with the SNF industry. In reality, the issues have been present for years but only regionally, highlighted … Read more

Blast from the Past – Duties of Boards: An OIG Perspective

There are nearly 300 articles/posts on this site and from time to time, I’m going to repost an “oldie but a goodie” that is as applicable now as it was when I originally wrote it.  This is from July of 2009.  This follows well with Tuesday’s piece on OIG initiatives and SNFs…https://wp.me/ptUlY-BJ This seemed to … 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

SNFs, Therapy Contracts and Fraud: Another Warning and Example

I know I sound redundant but clearly, the message is still not permeating through the industry (except for readers here). The Department of Justice and the OIG for the Department of Health are scrutinizing SNFs, their therapy billings, and the use of therapy contractors.  Why?  It is all due to a known and now routinely … Read more

Post-Acute Compliance 2015: OIG Targets

As is customary in late fall, the Office of the Inspector General (OIG) of the Department of Health and Human Services released its Fiscal Year work plan.  As a reminder or preface, the work plan is the summary of investigations and focal areas the OIG plans to undertake in the upcoming fiscal year and beyond … Read more

SNFs: Five Compliance Issues to Pay Attention To

I don’t write a lot on compliance issues. Given the scope of my firm’s practice in this area, maybe I should.  My practice focus is more strategic, policy, research  and corporate development while compliance is the purview of another Sr. Partner and it is our largest practice area (by full disclosure, this practice area is … Read more

United States v. Vitas: The Impact and What Next

On May 5, the U.S. Department of Justice released its most recent complaint (legal suit filed in Federal court) against Chemed, the corporate parent of Vitas.  The complaint is a False Claims Act suit.  Briefly for the uninitiated, a False Claims Act suit alleges that the Medicare provider knowingly (or unknowingly but once discovered, did … Read more

Hospice Tumult: The Beggining of the End?

Over the past couple of months or so, I’ve watched rather intently, the developing storm clouds in the Hospice industry. Suffice to say, what is now apparent takes the form of a perfect storm.  For industry “watchers”, the news regarding Vitas and the amalgamation of federal false claims act suits is a reflection on the … Read more

Hospice Outlook: 2013

The smallest provider centric benefit (by outlay) under Medicare is also one of the fastest growing in terms of expenditures and agency growth.  Lately, it’s arguably become the most controversial in terms of payment and expenditure growth correlated with fraud.  In the past year, the industry saw multiple large-scale investigations and ultimately, legal actions and OIG/Department of Justice … Read more