Category Archives: Assisted Living

OIG 2014 Work Plan – Hospice

This article represents another installment of a series of articles that will outline the OIG’s activities, as discussed in the 2014 work plan, for a specific industry sector – hospice.

For 2014, the OIG’s activities relating to hospices are focused on the provision of hospice services in assisted living facilities, and quality of care.

Hospice in Assisted Living Facilities

Pursuant to the Affordable Care Act, CMS is required to reform the hospice payment system, collect data relevant to revising hospice payments, and develop quality measures for hospices. Hospice care is currently provided in a variety of settings, including private residences, skilled nursing facilities, and assisted living facilities. Continue reading

Office of Inspector General Issues Strategic Plan

The Office of the Inspector General (“OIG”) issued a 2014-2018 strategic plan including outlining the visions, goals, and priorities of that office for the upcoming several years. The plan sets forth four goals: 1. Fight fraud, waste and abuse; 2. Promote quality, safety, and value; 3. Secure the future; and 4. Advance excellence and innovation. Each goals is identified with several priority areas that support the stated goal. The report can be found at the OIG’s website http://go.us.gov/WdbV

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

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

OIG Report: Home and Community-Based Services in Assisted Living Facilities – Federal and State Compliance Deficiencies

On December 10, 2012, the US Department of Health and Human Services Office of the Inspector General’s (OIG) Office of Evaluation and Inspections issued a report (OEI-09-08-00360) entitled “Home and Community-Based Services in Assisted Living Facilities”.

The OIG conducted a review of 35 State Medicaid programs  from 2009 that are covered under 1915(c) waivers.  The 1915(c)  waiver allows State Medicaid programs flexibility through CMS’s waiver of certain State plan requirements.   The review identified the types of home and community-based services (HCBS) that are furnished for Medicaid beneficiaries, the number of beneficiaries that receive HCBS while residing in assisted living facilities (ALF), the annual cost of furnishing the HCBS, and whether the documentation of provider standards existed.  Continue reading