Category Archives: Post Acute Care

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

CMS Directs MACs to Reject Part B Ambulance Claims for SNF to SNF Transfers

On November 6, 2013, CMS issued Transmittal No. 1311 which instructed Medicare Administrative Contractors (“MACs”) to reject claims for SNF to SNF ambulance transfers that are billed separately under Part B. According to CMS, ambulance transportation and related ambulance services for residents in a Part A stay are included in the SNF PPS rate and may not be billed as Part B services by the supplier. Instead, the SNF discharging the beneficiary to another SNF is responsible for the transportation fees. As such, ambulance providers must seek payment from the transferring SNF. Continue reading

Long Term Care Facilities Should Anticipate Increased Scrutiny on Nursing Home Trust Fund Oversight

USA Today recently published a report about theft from nursing home resident trust funds by facility employees. According to USA Today’s analysis of data from the Centers for Medicare and Medicaid Services (“CMS”), more than 1,500 nursing homes have been cited since 2010 for mismanaging trust funds—of the more than 100 thefts identified, at least 10 exceeded $100,000. The report warns about inadequate oversight, at both the nursing home and state surveyor level, to effectively protect the integrity of resident funds from employee theft. Continue reading

CMS Issues Guidance on CPR in Nursing Facilities

The first Survey & Certification memo for nursing facilities was issued for Fiscal Year 2014 on October 1, 2013. S&C 14-01-NH requires nursing facilities to adopt a policy that implements basic life support measures such as basic CPR for residents in accordance with the individual resident’s advance directives. Some nursing facilities have previously adopted a policy that when a resident is found without vital signs and the resident was a full code, the facility called 911 and waited for a response from the emergency personnel. CMS has affirmatively stated that the facility implement CPR when cardiac arrest occurs for residents in accordance with their advance directives and merely waiting for emergency personnel to respond to the 911 call is inadequate. CPR certified staff must be available at all times to provide CPR when necessary. Facilities will be cited under F155 for violating a resident’s right to formulate an advance directive if the facility does not develop and successfully implement policies and procedures to assure that residents will be resuscitated in accordance with their individual advance directives.

You can find a copy of  the letter here —> S&C 14-01-NH

For more information on the Survey Letter or related issues, please feel free to contact Janet Feldkamp or any member of our health care practice group for a further discussion.