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CMS Updates Requirements to Reduce Legionella Risk in Health Care Facility Water Systems and Identifies Surveyor Expectations – Review of Policies and Procedures Required

[07/12/18]

Posted on July 12, 2018 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

On July 6, 2018, the Survey and Certification Group at the Centers for Medicare & Medicaid Services (“CMS”) revised its memorandum, “Requirement to Reduce Legionella Risk in Healthcare Facility Water Systems to Prevent Cases and Outbreaks of Legionnaires’ Disease (LD)” (“S&C Memo”), that requires that facilities develop and follow policies and procedures that inhibit... READ MORE

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CMS Seeks Input on Stark Law Changes to Accelerate the Shift to Value-Based Care

[06/22/18]

Posted on June 22, 2018 in Health Law News

Published by: Hall Render

On June 20, 2018, the Centers for Medicare & Medicaid Services (“CMS”) issued a Request for Information (“RFI”) seeking feedback from health care industry stakeholders on the burdens of compliance with the Stark Law as it exists today. Earlier in the day, Kelly Cleary from the HHS Office of the General Counsel and HHS... READ MORE

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CMS Announces New Opioid Safety Measures for Part D Plan Sponsors: What Is Really Going On?

[05/23/18]

Posted on May 23, 2018 in Health Law News

Published by: Hall Render

The Centers for Medicare & Medicaid Services (“CMS”) recently finalized several new policies aimed at preventing and combating prescription opioid misuse by Medicare Part D beneficiaries. The policies, detailed in CMS’s 2019 Final Call Letter (“Call Letter”)[1] and outlined below, require Part D plan sponsors to implement various safety measures to reduce opioid overuse among... READ MORE

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CMS Proposes to Eliminate Written Physician Order Requirement as a Condition for Payment for Inpatient Admissions

[05/08/18]

Posted on May 8, 2018 in Health Law News

Published by: Hall Render

On April 24, 2018, the Centers for Medicare & Medicaid Services (“CMS”) issued its proposed rule for the CY 2019 Inpatient Prospective Payment System (“Proposed Rule”). Among many other changes, one very important change stands out in the Proposed Rule, specifically eliminating the requirement that providers record a written inpatient admission order in the medical... READ MORE

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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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