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CMS Issues 18-Month Moratorium and Delays Enforcement of Some Phase 2 Requirements for Long-Term Care Facilities

[11/27/17]

Posted on November 27, 2017 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

This is another article in a series discussing the complete overhaul of Part 483 to Title 42 of the Code of Federal Regulations, the Requirements for States and Long-Term Care Facilities (“Final Regulations”) by the Centers for Medicare & Medicaid Services (“CMS”). BACKGROUND On September 28, 2016, CMS released a complete overhaul of Part... READ MORE

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CMS Issues Draft of Interpretive Guidelines for the Conditions of Participation for Home Health Agencies

[11/01/17]

Posted on November 1, 2017 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

The Centers for Medicare & Medicaid Services (“CMS”) released a draft of the Interpretive Guidelines (“Draft Interpretive Guidelines”) to the final Conditions of Participation (“CoPs”) for home health agencies that CMS issued in January 2017. The CoPs are scheduled to be implemented January 13, 2018. CMS has asked for feedback on the Draft Interpretive Guidelines. The Draft... READ MORE

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Countdown to Phase II Compliance: The Facility Assessment for Long-Term Care Facilities – Review of Facility Resident Population and Resources Required

[08/22/17]

Posted on August 22, 2017 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

This is another article in a series discussing the complete overhaul of Part 483 to Title 42 of the Code of Federal Regulations, the Requirements for States and Long-Term Care Facilities (“Final Regulations”) by the Centers for Medicare & Medicaid Services (“CMS”). Hall Render published an overview of Final Regulations components as well as Parts 1,... READ MORE

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CMS Revises CMP Policies and Analytic Tool CMS Uses to Impose Fines – Opportunities Exist for Facilities to Reduce CMPs

[08/01/17]

Posted on August 1, 2017 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

On July 7, 2017, the Survey and Certification Group at Centers for Medicare & Medicaid Services (“CMS”) issued a memorandum, “Revision of Civil Money Penalty (“CMP”) Policies and CMP Analytic Tool” (“S&C Memo”) detailing revisions to policies and the analytic tool used to assess and determine CMPs for skilled nursing facilities. The stated goal is... READ MORE

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CMS Issues Clarification of Notice Requirements to Long-Term Care Ombudsman when Resident Is Transferred or Discharged from Long-Term Care Facility – Review of Practices, Policies and Procedures Required

[07/24/17]

Posted on July 24, 2017 in Health Law News, Long-Term Care, Home Health & Hospice

Published by: Hall Render

This is another article in a series discussing the complete overhaul of Part 483 to Title 42 of the Code of Federal Regulations, the Requirements for States and Long-Term Care Facilities (“Final Regulations”) by the Centers for Medicare & Medicaid Services (“CMS”). Hall Render published an overview of Final Regulations components as well as Parts 1,... READ MORE

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CMS Issues Requirement to Reduce Legionella Risk in Health Care Facility Water Systems – New Policies and Procedures Required

[07/17/17]

Posted on July 17, 2017 in Health Law News, Long-Term Care, Home Health & Hospice

Published by: Hall Render

On June 2, 2017, the Survey and Certification Group at the Centers for Medicare & Medicaid Services (“CMS”) issued a memorandum, “Requirement to Reduce Legionella Risk in Healthcare Facility Water Systems to Prevent Cases and Outbreaks of Legionnaires’ Disease (LD)” (“S&C Memo”), requiring that facilities develop and follow policies and procedures that inhibit microbial growth... READ MORE

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CMS Issues Guidance Suspending Enforcement of Penalties for Phase 2 Requirements and Revises F-Tags

[07/11/17]

Posted on July 11, 2017 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

This is another article in a series discussing the complete overhaul of Part 483 to Title 42 of the Code of Federal Regulations, the Requirements for States and Long-Term Care Facilities (“Final Regulations”) by the Centers for Medicare & Medicaid Services (“CMS”). BACKGROUND On September 28, 2016, CMS released a complete overhaul of Part... READ MORE

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Reasonable Assurance Period and Voluntary Termination When an Enforcement Action Is Pending Against a Medicare Certified Provider or Supplier

[06/29/17]

Posted on June 29, 2017 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

On June 16, 2017, CMS issued transmittal S&C: 17-35-ALL. This transmittal clarified CMS policy by stating a reasonable assurance period will apply if a provider or supplier voluntarily terminates its Medicare certification when an enforcement action has been initiated by the State Survey Agency. Section 2016 of the State Operations Manual allows a provider... READ MORE

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CMS Proposes Format Changes for Plans of Correction and Allegations of Compliance

[06/28/17]

Posted on June 28, 2017 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

On June 16, 2017, CMS issued transmittal S&C: 17-34-ALL. This transmittal set forth changes to the format of Plans of Correction (“POC”) and Allegations of Compliance (“AOC”). Providers will no longer be required to write their POC/AOC on the right side of the CMS Form 2567 (“2567”). Providers are now allowed to submit the... READ MORE

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21st Century Cures Act Lessens EHR Burdens on Physicians Performing Cases in ASCs

[02/21/17]

Posted on February 21, 2017 in Health Law News

Published by: Hall Render

The Cures Act addresses certain electronic health record (“EHR”) difficulties faced by physicians who practice primarily in ambulatory surgery centers (“ASCs”). Section 16003 explicitly excludes physicians who furnish substantially all of their Medicare services at ASCs from the penalties imposed under various programs for failure to adopt a certified EHR. Under the current Medicare... READ MORE

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