Healthcare, Senior Living, Economics
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
In 1998, CMS created the Special Focus Facility initiative or program designed to target or focus attention on improving the poorest performing facilities (performance defined by survey/compliance history). Each state selects up to 15 of the poorest performing facilities until the program reaches its cap or maximum of 136 facilities. The requirements from CMS to … Read more
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
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
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
In March, I wrote about the MedPAC recommendations to change the Medicare Hospice program and payment system. Yesterday, CMS announced the final (2010) payment for Hospice as well as the implementation structure of some key MedPAC recommendations. The final rule will be published August 6th in the Federal Register. For FY 2010 (commencing October 1), … Read more
This seemed to be a natural successor topic to my last post, “Why Quality Matters”; principally arising out of recent press releases from the OIG. For example, in June the OIG reported that it had recovered $2.4 Billion in fraud, waste and abuse. In July, an OIG release reported that a Nursing Home Executive was banned … Read more