The Medicare Payment Advisory Commission’s (“MedPAC”) recent Report to Congress included a chapter dedicated to skilled nursing facilities (“SNFs”), which MedPAC reports received $31 billion in Medicare reimbursement in 2011. Recently, SNFs have been under pressure from repeated reimbursement cuts; however, MedPAC’s analysis states that SNF reimbursement is adequate. Continue Reading →
Long Term Care
The Medicare Payment Advisory Commission’s (“MedPAC”) March 25th Report to Congress outlines inefficiencies they believe exist in the post-acute world and lead to excessive Medicare payments to providers. MedPAC recommendations include Congress evaluate post-acute provider reimbursement and encourage use of the lowest cost mix of services necessary to achieve the best outcomes.
The Centers for Medicare & Medicaid Services (“CMS”), in the March 8, 2013 Memorandum, issued new guidance specifying those tasks that can and cannot be delegated in skilled nursing facilities (“SNFs”) and nursing facilities (“NFs”). Physicians who improperly assign tasks to non-physician practitioners (“NPPs”) jeopardize the SNFs’ and NFs’ compliance with federal and state regulations, which potentially affects the facilities’ reimbursement.
The Centers for Medicare & Medicaid Services, in the March 8, 2013 S & C 13-16 NH, revised the Interpretative Guidelines for F-Tag 155 (“Advance Directives”) in Appendix PP of the State Operations Manual. This memorandum updates S & C 12-47.
According to the Centers for Medicare & Medicaid Services (“CMS”), since 1972, there have been in excess of 100 reports of Luer misconnections that have resulted in adverse events. Recently, a patient’s blood pressure tubing was misconnected to an intravenous line in an ambulatory surgical center (“ASC”) that resulted in the patient’s death. Generally, the patients most often affected with the misuse of Luer connectors are those with multiple tubing. However, the aforementioned incident involved a patient undergoing carpal tunnel surgery in an ASC. Continue Reading →
Based on additional feedback, the Centers for Medicare & Medicaid Services (CMS) has revised the surveyor guidance issued in September 2012 on Naso-Gastric Tubes (NG Tubes) for F-Tag F322. Since the NG Tube regulation, §483.25(g), was published, the use of NG Tubes has become increasingly rare in favor of other forms of enteral feeding tubes. Recognizing this, CMS is considering all forms of enteral feeding tubes as NG Tubes solely for purposes of the interpretive guidance of F-Tag F322.
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or your regular Hall Render attorney.
The Office of Inspector General (“OIG”) released a report on March 6 that showed a significant number of long-term care hospitals (“LTCHs”) that are co-located with skilled nursing facilities (“SNFs”) or acute care hospitals are failing to notify their Medicare Administrative Contractors (“MACs”) or fiscal intermediaries (“FIs”) of their co-located status. The notification of co-located status is required by LTCH prospective payment system (“PPS”) regulations and can affect reimbursement policies for certain LTCHs that exceed specified readmission thresholds. Failure to appropriately apply the reimbursement policies could result in Medicare overpayments for services provided to beneficiaries in LTCHs.
McKnight’s published an article this morning on the rise in Carbapenem-Resistant Enterobacteriaceae (CRE) in long-term care facilities. The Center for Disease Control & Prevention (CDC) states these bacteria kill about half of all people who become infected, and are resistant to antibiotic treatments. These CRE bacteria are even resistant to the antibiotics “of last resort” and can transfer their resistance to other kinds of bacteria. Continue Reading →
The Centers for Medicare & Medicaid Services (CMS) has unofficially announced it will not be enforcing the upcoming March 23rd compliance program requirements until final regulations are published. As required under the Affordable Care Act, nursing facilities are required to have a compliance program in place by March 23, 2013. Despite ambiguity in the actual statute, which states a facility must have a compliance program in place “on or after” March 23rd, this is widely accepted in the industry as the date for the requirement to be effective. Continue Reading →
In 2003, two fires in long-term care facilities resulted in 31 resident deaths. As a result of these two events, CMS analyzed the fire safety precautions in place in these facilities and determined that resident safety could be greatly improved by requiring that all long-term care facilities have automatic sprinkling systems installed throughout the buildings. Consequently, on August 13, 2008, CMS published a final rule that required all buildings with long-term care facilities must have automatic sprinkler systems installed throughout the facilities no later than August 13, 2013.