Archive | Long-Term Care

Long Term Care

CARES Act Introduced: Would Waive Three-Day Stay for Certain SNFs

The Creating Access to Rehabilitation for Every Senior Act of 2013 (“Bill”) was introduced this week by Representative James Renacci (R-OH) to the House.  This Bill proposes to waive the three-day qualifying stay requirement for admission to a skilled nursing facility (“SNF”) under Medicare.   Continue Reading →

CMS Revises Citation Guidelines for Facilities Working Towards Sprinkler Compliance

The Centers for Medicare & Medicaid Services (“CMS”) just released a revision to their August Survey and Certification letter concerning the August 13, 2013 deadline for the installation of automatic sprinkler systems in nursing facilities. Originally, facilities that did not meet the deadline were subject to deficiencies at scope and severity (“S&S”) levels of D, E or F. Recognizing that some facilities are still in the process of compliance, CMS has enumerated 10 protections that, if in place, may permit the deficiency citation to be reduced to an S&S level of C. Continue Reading →

Medicare Administrative Contractors Announce Intent to Review Hospice Claims

On October 30, two Medicare Administrative Contractors, Palmetto GBA and CGS, announced their intent to focus on certain hospice claims for patients located in Skilled Nursing Facilities (“SNFs”).

Palmetto GBA announced that it has identified top providers with a large number of beneficiaries receiving hospice services in SNFs, and it intends to initiate a service-specific investigation of claims for beneficiaries with non-cancer diagnoses.  While the claim’s timeframe is unknown, the investigation will be initiated in Jurisdiction 11, which covers home health and hospice services in Alabama, Arkansas, Florida, Georgia, Illinois, Indiana, Kentucky, Louisiana, Mississippi, New Mexico, North Carolina, Ohio, Oklahoma, Tennessee and Texas.  Once complete, review results will be posted on the Palmetto GBA website and individual providers may be contacted for one-on-one education. Continue Reading →

CMS Deletes Certain Citations Under §483.70(a), Associated Tag F-454

Effective October 25, 2013, CMS deleted citations for tag F-454 under 42 C.F.R. §483.70(a) pertaining to Physical Environment—Life Safety From Fire.  CMS noted, because these requirements are covered under the Life Safety Code (“LSC”), there was a duplication of findings and, therefore, only needed to be cited under the appropriate LSC K Tag requirements.  This change will benefit providers in that survey deficiencies will be more accurately and more appropriately cited for alleged LSC violations. Continue Reading →

CMS Issues Guidance on Survey and Certification Activities During Government Shutdown

Executive Summary

On October 1, 2013, the Centers for Medicare & Medicaid Services (“CMS”) released a Survey and Certification Letter (“S&C Letter”) that identified how the governmental shutdown (“Shutdown”) will affect state survey agency (“SA”) functions for all providers and suppliers. The S&C Letter delineates what SA functions are essential to ensure the protection of Medicare and Medicaid beneficiaries against immediate dangers to life and health and to prevent providers and suppliers from experiencing harm that would threaten their ability to provide vital health care services to Medicare and Medicaid beneficiaries. Continue Reading →

Preliminary Impact of Government Shutdown on LTC Providers–UPDATE

The Centers for Medicare & Medicaid Services (“CMS”) issued a Survey & Certification Memo (“S&C Letter”) to state agencies detailing the result of the governmental shutdown on long-term care providers as it relates to surveys.  As of this writing, the S&C Letter has not been published or otherwise made publicly available, and the below information has not been independently confirmed.  This information should not be relied upon until verification is available and is being provided for informational purposes only.  Please see the update below.  Continue Reading →

Expansion of IIDR

Beginning October 1, 2013, a skilled nursing facility (“SNF”), a nursing facility (“NF”) or a dually-certified SNF/NF will be permitted to request an independent informal dispute resolution (“IIDR”) for all federal deficiencies cited on its standard or complaint survey (CMS-2567) that are subject to the imposition, collection and escrow of civil money penalties (“CMPs”) by the Centers for Medicare & Medicaid Services.  Currently, only SNFs, NFs and SNF/NFs with federal deficiencies cited at a “G” or higher level (actual harm or immediate jeopardy) are subject to the CMP collection and escrow process and are permitted to request an IIDR.  After October 1, 2013, the opportunity to request an IIDR will be afforded to all affected facilities.

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