CMS Proposed Rules for Immediate Jeopardy Situations for Providers Other than SNFs and NFs

Posted on May 17, 2013 by | Leave a comment

In the April 5th Federal Register, the Center for Medicare and Medicaid Services (CMS) proposed new rules relating to immediate jeopardy situations for providers or suppliers that are not Skilled Nursing Facilities (SNFs) or Nursing Facilities (NFs). The proposed rules were published in April of 2013 in the Federal Register and generally apply to the oversight of accrediting organizations, but CMS also proposed a changed to the rule on providers and suppliers, other than SNFs and NFS, with deficiencies. Continue reading →

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Posted in Acute Care, Certification, Continuing Care, DAB Decisions, DHHS, Health & Human Services, Health Care, Health Care Providers, Home Health, Hospice, Hospital, Intermediate Care Facility, Long Term Care, Medicare, Nursing Facility, Nursing Home, Participation, Post Acute Care, Proposed Rule, Regulation, Regulatory Compliance, Rehabilitation, Rehabilitation Hospital, Residential Care, Skilled Nursing Facility

OIG Issues Report Finding Inconsistencies in Medicare Billing for Hospice Inpatient Stays

Posted on May 8, 2013 by | Comments Off

On May 3, 2013, the US Department of Health and Human Services Office of the Inspector General’s (OIG) Office of Evaluation and Inspections (OEI) issued a report (OEI-02-10-00490) entitled “Medicare Hospice:  Use of General Inpatient Care.”  The report found that while Medicare paid $1.1 billion for hospice general inpatient care (“GIP”) in 2011, there were unusual Medicare billing patterns for hospice inpatient stays, raising concerns about whether the stays were billed appropriately and whether the patients received the right level of care. Continue reading →

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Posted in DHHS, Fraud and Abuse, Health Care, Health Reform, Hospice, Medicare, OIG Reports, Post Acute Care, Program Integrity, Quality Improvement Organizations

Webcast on ACA and “Smart Workforce Strategies”

Posted on May 1, 2013 by | Comments Off

April 24 Webcast on ACA and ‘Smart Workforce Strategies’ Now Available

The implications of the Affordable Care Act and what providers should be doing about it were the focus of an April 24 McKnight’s webcast led by Benesch Health Care partner Janet Feldkamp. The event is now available for viewing in the McKnight’s archive. Attendees need only either log in to their existing account or register for free to access the presentation by clicking here: http://video.webcasts.com/events/pmny001/viewer/index.jsp?eventid=45826&adid=MCK1

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Posted in Health Care

HRSA Announces Merger of NPDB and HIPDB

Posted on April 22, 2013 by | Comments Off

The Health Resources and Services Administration (HRSA) has announced that the Healthcare Integrity and Protection Data Bank (HIPDB) and the National Practitioner Data Bank (NPDB) will merge on May 6, 2013.  On that date, the HIPDB will close down, and all future reporting must be done through the NPDB.

While the databases are merging, there has been no change in the reporting requirements.  Any user who was previously required to report information to the HIPDB must now do so through the NPDB. All information currently in the HIPDB will now be available through the NPDB. Continue reading →

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Posted in Exclusion, Final Rule, Health Care, Health Care Providers, Health Reform, Hospital, Long Term Care Hospital, Nursing Facility, Nursing Home, Out-Patient Care, Physicians, Regulatory Compliance, Rehabilitation Hospital, Skilled Nursing Facility

OIG Publishes Special Fraud Alert regarding Physician-Owned Distributors (“PODs”) – Describes PODs as “Inherently Suspect”

Posted on April 16, 2013 by | Comments Off

Over the last several years, there has been a noted proliferation in the growth of physician-owned distributors (“PODs”). Along with this growth has come increased scrutiny and speculation as to the legality of PODs, with highly vocal critics and proponents on both sides of the debate. In fact, the Office of the Inspector General’s (“OIG”) 2013 Work Plan noted that the OIG planned to examine PODs in connection with reports of high utilization of spinal implants by hospitals associated with PODs.

Accordingly, on March 26, 2013, the OIG released a Special Fraud Alert (the “Fraud Alert”) which provides long-awaited guidance concerning the legality of PODs. Continue reading →

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Posted in Anti-Kickback, DHHS, Fraud and Abuse, Health Care, Health Care Providers, OIG, Out-Patient Care, Physicians, Primary Care, Program Integrity, Regulatory Compliance, Special Fraud Alert, Supplier

Spring Cleaning – Dust Off Your Compliance Program Manual and Take Some Practical Steps to Reinvigorate Your Program.

Posted on March 22, 2013 by | Comments Off

Compliance program fatigue is nothing new. Over at least the last 15 years, health care organizations have jumped in head first, put together detailed manuals and taken the plunge. However, reimbursement cuts, quality initiatives, RACs, ZPICs, whistleblowers, physical plant renovations and simply significant industry challenges got in the way of sustaining an efficient and effective compliance effort. Health care organizations have also become desensitized to the barrage of compliance education, enforcement press releases, audits and reviews and other shock-value communications on the importance of regulatory compliance. In that vein, this very article may get lost in the shuffle, although, we hope it doesn’t.

An efficient and effective compliance effort with your organization is extremely important, if only as an insurance policy against government scrutiny. Additionally, the Patient Protection and Affordable Care Act of 2010, H.R. 3590 (“ACA”) includes requirements that CMS implement mandatory compliance program requirements for all providers and suppliers. In a distinct section of ACA, nursing home mandatory compliance programs were given a specific implementation timeline. Continue reading →

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Posted in Acute Care, Adult Home, Ambulatory Surgery Centers, Assisted Living, Clinical Laboratory, Clinics, Community Based Care, Compliance Programs, Continuing Care, Diagnostic Testing, Disability, Durable Medical Equipment, Fraud and Abuse, Group Home, Health Care, Health Care Providers, Health Information Privacy, Health Reform, Home Health, Hospice, Hospital, Intermediate Care Facility, Long Term Care, Long Term Care Hospital, Medicare, Mental Health, Nursing Facility, Nursing Home, Occupational Therapy, Out-Patient Care, Palliative Care, Pharmacy, Physicial Therapy, Physician Assistants, Physicians, Post Acute Care, Primary Care, Program Integrity, Regulatory Compliance, Rehabilitation, Rehabilitation Hospital, Residential Care, Senior Housing, Skilled Nursing Facility, Supplier

New Ohio Law Requires Employers to Notify Patients of Termination of Physician’s Employment

Posted on March 19, 2013 by | Comments Off

Under new Ohio Revised Code § 4731.228, which becomes effective on March 22, 2013, hospitals, physician practices and other entities employing physicians in Ohio will be required to send patient notices when a physician’s employment is terminated. This notice must go to all patients seen by the physician in the previous two years and must be sent by the later of the date the physician’s employment is terminated or 30 days from when the employer has actual knowledge of the physician’s termination or resignation. The notices may be sent by the employer, or the employer may require the physician to send the notices. Continue reading →

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Posted in Health Care, Health Care Providers, Ohio, Out-Patient Care, Physicians, Primary Care