CMS Issues Updates on Immediate Jeopardy

Back in 2019, CMS issued revisions to Appendix Q of the State Operations Manual pertaining to Immediate Jeopardy considerations (on the part of surveyors) and ultimately, citation decisions.  This guidance was relevant for all provider and supplier types participating in Medicare (hospitals, home health, SNFs, etc.). In late October, CMS issued guidance on penalties. What … Read more

Friday Feature: Four Topics to Watch

It has been a busy week and next week is a holiday week (Thanksgiving) so of course, a shortened news and work week. That said, there is a lot going on right now and for followers and readers, I thought sharing my top four topics to watch made sense. Tort Reform: Back in February, the Georgia … Read more

CMS Reinforces Hospice Regulatory, Fraud Focus

Yesterday, CMS dropped a memo to state survey agencies titled, “Ensuring Consistency in the Hospice Survey Process to Identify Quality of Care Concerns and Potential Fraud Referrals”. The memo is available here: qso-25-06-hospice According to CMS, the memorandum aims to bolster current mechanisms for detecting instances where a hospice provider’s failure to adhere to the … Read more

SNF Survey and Certification Update

When the 2025 Final SNF PPS Rule was released, the focus was on Medicare rate increases.  This is typically known as the “headline”. But as readers and followers here know, there is always a regulatory tidbit or two that can be even more significant in terms of operations, particularly as more and more Medicare patient … Read more

Defend Your Long-Term Care Facility Against Litigation with Expert Data Analysis

My firm has a unique practice concentration in the area of complex litigation. Our expertise is principally on the defense side of claims. Our team assists long-term care providers in leveraging intricate data to safeguard against legal disputes and adverse public opinion. We help clients discover methods to analyze and utilize data from government, consumers, … Read more

Hospice Special Focus, IDR, and Quality Reporting Program – 2024

Somewhat buried within the Home Health Final Rule (PPS) was an update on a CMS initiative to identify hospice agencies requiring additional regulatory oversight for poor care performance (poor quality, unsafe care practices). Back in 2021, CMS began the Special Focus initiative and in the 2024 Hospice Final Rule, CMS indicated that the recommendations for … Read more

Senators Seek Survey Accountability for SNFs

Last Thursday, Senators Bob Casey (Pennsylvania), Ron Wyden (Oregon), and Chucky Grassley (Iowa) sent a letter to CMS asking that the agency “take immediate steps to strengthen the nursing home oversight system”. Their letter is a follow-up to a report from the Senate Committee on Aging, chaired by Casey, detailing a myriad of problems with … Read more

Hospice Contracts in SNFs: Survey Reminders for the SNF

Due to a fair amount of travel recently, I’m a tad behind in pushing out updates, etc.  Despite my rather harried schedule, I have kept track of questions, issues, etc. and in the next week to ten days, I will endeavor to get caught up.  Please know that I do appreciate the comments and questions … Read more