Category: Medicaid/Medicare Enrollment and Regulatory Compliance

Revised RAI Manual Effective October 1

The most recent revisions to the Resident Assessment Instrument (“RAI”) User’s Manual became effective yesterday for all assessments with an assessment date on or after October 1.  The significant portion of the revisions addresses changes to therapy coding and swallowing and nutrition.  … Continue Reading →

Bill Introduced to Remove Hospital Stay Requirement for SNFs

Prior to the government shutdown, Representative Jim McDermott of Washington introduced a bill that would end the hospital inpatient requirement for skilled nursing facility (“SNF”) coverage.  … 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 →

CMS Clarifies Qualifying Stay in VA Hospital

One of the main admission requirements for a skilled stay in a skilled nursing facility (“SNF”) is a three-day qualifying stay in an inpatient hospital.  In response to a question discussed on a recent Open Door Forum, the Centers for Medicare & Medicaid Services (“CMS”) released a memorandum discussing if a stay in a Department of Veterans Affairs Hospital (“VA Hospital”) can count as a qualifying stay for Medicare purposes.   … Continue Reading →

CMS Five-Star Rating Report Shows Nursing Home Quality Rising

The Centers for Medicare & Medicaid Services (“CMS”) has rated nursing facilities since 2009 for three areas of performance: Health Inspections, Staffing, and Quality Measures. From 2009 through 2011, more than 40% saw an improvement in overall rating, while only around 27% had a most recent rating that was lower than the first.  … Continue Reading →

CMS Issues Reminder Regarding 24-Hour Visitation

The Centers for Medicare & Medicaid Services (“CMS”) issued a Survey and Certification Letter as a reminder of current regulations (42 C.F.R. 483.10(j)) delineating the rights of long term care (“LTC”) residents to receive family and non-family visitors.  The current guidelines grant broad discretion to the residents with respect to visitation.  Facilities must provide 24-hour visitation rights to all individuals with the resident’s consent.  … Continue Reading →

CMS Releases FY 2014 SNF PPS Rates, Updates Therapy Day Reporting Requirements

The Centers for Medicare & Medicaid Services (“CMS”) recently released the final rule for fiscal year (“FY”) 2014 skilled nursing facility (“SNF”) prospective payment system (“PPS”) rates.  These rates will take effect October 1, the start of FY 2014.  … Continue Reading →

OCR Online

On July 12, 2013, CMS issued S&C: 13-46-ALL regarding changes for State Survey Agency (“SA”) obtaining OCR information from providers seeking initial enrollment in the Medicare program or for providers undergoing a change of ownership (“CHOW”).  In the past, the SAs would send the provider an OCR clearance request with the initial Medicare enrollment packet.  The SA must now offer the provider the option to answer all OCR clearance questions online.  These changes are effective July 15, 2013.

Continue Reading →

CMS Publishes QAPI Toolkit and Other Resources

Originally due last Fall, the Centers for Medicare & Medicaid Services (“CMS”) has published the Quality Assessment and Performance Improvement (“QAPI”) Provider Toolkit and Provider Resources for skilled nursing facilities (“SNFs”).  These items have been published on a new CMS website dedicated to helping SNFs develop and implement a QAPI program, as required by the Affordable Care Act (“ACA”).  … Continue Reading →

CMS Revises Policy as to Surveys to Be Conducted Following Complaint Investigations Resulting in Condition-Level Noncompliance

The Centers for Medicare & Medicaid Services (“CMS”) recently released a Survey and Certification letter updating the State Operations Manual (“SOM”) guidelines  on surveys of deemed status long-term care (“LTC”) providers when the provider has been found to have a condition level instance of noncompliance, including immediate jeopardy (“IJ”), in a complaint survey.  This change in policy only applies to “deemed status providers.”  Deemed status is available when an approved accrediting organization (“AO”), separate from CMS, determines the provider is in compliance with Medicare conditions.  This “deemed status” will largely exempt the provider from routine surveys by the State Agency (“SA”) but still requires the provider to comply with all applicable Medicare conditions.  Nursing facilities are largely not eligible for deemed status; however, home health agencies (“HHAs”) and hospice and rehabilitation agencies are eligible.

Continue Reading →