Category Archives: Long Term Care Hospital

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

Report on Results of Administrator Survey – Nationwide Program for Background Checks for Long-Term Care Employees

On January 19, 2012, the Office of Inspector General (“OIG”) released its Memorandum Report on the results of a long-term care provider administrator survey conducted pursuant to the Nationwide Program for National and State Background Checks on Direct Patient Access Employees of Long-Term-Care Facilities and Providers (the “Program”).  The Program, established under Section 6201 of the Patient Protection and Affordable Care Act (“PPACA”), is a voluntary program that provides grants to states to implement procedures to conduct background checks on prospective long-term care employees.  The purpose of the OIG’s Memorandum Report was to report on the results of a survey that was conducted in order to collect baseline data on current background check practices in the long-term care industry. Continue reading

CMS Provides Guidance on PAs Performing SNF Certifications and Recertifications

CMS recently issued Transmittal 153, entitled –  “Allowing Physician Assistants to Perform Skilled Nursing Facility (SNF) Level of Care Certifications and Recertifications”.  The transmittal provides guidance on the ability of physician assistants to perform level of care certifications and recertifications in skilled nursing facilities. The guidance implements Section 3108 of the Affordable Care Act.  According the guidance, a physician assistant may now perform the certification or recertification if the physician assistant collaborates with the physician but does not have a direct or indirect employment relationship with the facility.  The new rules become effective for items and services furnished on or after January 1, 2011.

You can find a copy of the new guidance here —> Transmittal 153