Category Archives: Acute Care

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

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

OIG Advisory Opinion 12-22 – No Sanctions Imposed For Hospital’s Bonus Payments to Physician Group

Posted on January 17, 2013 by | Comments Off

On December 31, 2012, the OIG issued a favorable Advisory Opinion, No. 12-22, concerning a cardiology co-management agreement between a hospital and a private cardiology group practice (the “Management Agreement”).  Although the  Management Agreement potentially implicates the Anti-Kickback Statute and includes bonuses provided to a physicians’ group in exchange for implementing quality-improvement and cost-saving measures at the hospital’s cardiac catheterization laboratories (the “Arrangement”), the OIG advised that it would not impose sanctions on the requesting parties under the Civil Monetary Penalty or the Anti-Kickback Statute.  Continue reading →

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Posted in Acute Care, Anti-Kickback, Fraud and Abuse, Health Care, Health Care Providers, Hospital, Medicaid, Medicare, OIG, OIG Advisory Opinions, Physicians, Program Integrity, Quality Improvement, Regulatory Compliance

OIG Report – Medicare Pays Twice for Outpatient Services Provided Before or During an Inpatient Stay

Posted on June 14, 2012 by | Comments Off

On June 4, 2012, the US Department of Health and Human Services Office of the Inspector General’s (“OIG”) Office of Audit Services issued a report (A-01-10-00508) entitled “Medicare Continues To Pay Twice for Nonphysician Outpatient Services Provided Shortly Before or During an Inpatient Stay”.

The OIG conducted an audit of hospitals and hospital out-patient providers during 2008 and 2009 and determined that Medicare made approximately $6.4 million in overpayments to hospital outpatient providers.  The overpayments were made for  services provided to beneficiaries within 3 days prior to the date of admission, on the date of admission, or during an inpatient prospective payment system (IPPS) stay.  The OIG found that overpayments occurred because: (1) provider controls failed to prevent or detect incorrect billing, (2) providers were unaware that beneficiaries were in-patients at other facilities, and (3) providers were unaware of or did not understand Medicare requirements. Continue reading →

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Posted in Acute Care, Clinics, Fraud and Abuse, Health Care, Health Care Providers, Hospital, Medicare, OIG, Out-Patient Care, Physicians, Program Integrity, Regulatory Compliance, Reimbursement