Articles and Blogs

survey

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

Tags: , , , , , , , , , , , , , ,

Extension of Due Date for Nursing Home Automatic Sprinkler Installation

[05/22/14]

Posted on May 22, 2014 in Long-Term Care, Home Health & Hospice

Written by: Selby, Todd J.

On May 16, 2014, CMS issued a Survey and Certification Transmittal (“Transmittal”) to the state survey agency directors providing infomation on how Medicare and Medicaid certifed long-term care facilities may obtain an extension of time for the installation of automatic sprinkler sytems.  The Transmittal sets forth the procedures on how a nursing home may seek an... READ MORE

Tags: , , , , , , , , , , , ,

Preliminary Impact of Government Shutdown on LTC Providers–UPDATE

[10/01/13]

Posted on October 1, 2013 in Long-Term Care, Home Health & Hospice

Written by: Bufford, David W.

The Centers for Medicare & Medicaid Services (“CMS”) issued a Survey & Certification Memo (“S&C Letter”) to state agencies detailing the result of the governmental shutdown on long-term care providers as it relates to surveys.  As of this writing, the S&C Letter has not been published or otherwise made publicly available, and the below... READ MORE

Tags: , , , , , , ,

Expansion of IIDR

[09/06/13]

Posted on September 6, 2013 in Long-Term Care, Home Health & Hospice

Written by: Selby, Todd J.

Beginning October 1, 2013, a skilled nursing facility (“SNF”), a nursing facility (“NF”) or a dually-certified SNF/NF will be permitted to request an independent informal dispute resolution (“IIDR”) for all federal deficiencies cited on its standard or complaint survey (CMS-2567) that are subject to the imposition, collection and escrow of civil money penalties (“CMPs”)... READ MORE

Tags: , , , , , , , , , , , , ,

Automatic Sprinkler System Requirement Now in Effect for Long-Term Care Facilities

[08/22/13]

Posted on August 22, 2013 in Long-Term Care, Home Health & Hospice

Written by: Selby, Todd J.

On August 13, 2013, all nursing facilities participating in the Medicare and Medicaid programs were required to be in compliance with the automatic sprinkler systems’ regulation that was published in a final rule on August 13, 2008. The regulation provided a five-year phase-in program to allow long-term care facilities (“Facilities”) to achieve compliance by... READ MORE

Tags: , , , , , , , , ,

CMS Revises Policy as to Surveys to Be Conducted Following Complaint Investigations Resulting in Condition-Level Noncompliance

[04/26/13]

Posted on April 26, 2013 in Long-Term Care, Home Health & Hospice

Written by: Bufford, David W.

The Centers for Medicare & Medicaid Services (“CMS”) recently released a Survey and Certification Letter updating the State Operations Manual (“SOM”) guidelines  on surveys of deemed status long-term care (“LTC”) providers when the provider has been found to have a condition level instance of noncompliance, including immediate jeopardy (“IJ”), in a complaint survey.  This change... READ MORE

Tags: , , , , , , , , ,

Sequestration Cuts Impact Nursing Homes and Post-Acute Care Providers

[04/10/13]

Posted on April 10, 2013 in Long-Term Care, Home Health & Hospice

Written by: Selby, Todd J.

In a transmittal issued on April 5, 2013, CMS provided guidance on survey activities that will be affected by the sequestration cuts.  The transmittal provides guidance on several areas that will have an immediate and potentially negative effect on nursing homes and post-acute care providers.  These changes will affect the survey process as conducted by the state survey... READ MORE

Tags: , , , , , , , , , , , , , , ,

CMS Revises NG-Tube Surveyor Guidance

[03/11/13]

Posted on March 11, 2013 in Long-Term Care, Home Health & Hospice

Written by: Bufford, David W.

Based on additional feedback, the Centers for Medicare & Medicaid Services (CMS) has revised the surveyor guidance issued in September 2012 on Naso-Gastric Tubes (NG Tubes) for F-Tag F322.  Since the NG Tube regulation, §483.25(g), was published, the use of NG Tubes has become increasingly rare in favor of other forms of enteral feeding... READ MORE

Tags: , , , , , , ,

OIG Publishes 2013 Work Plan

[10/05/12]

Posted on October 5, 2012 in Long-Term Care, Home Health & Hospice

Written by: Bufford, David W.

The Office of the Inspector General (OIG) has published their annual Work Plan for 2013. The Work Plan continues to identify compliance risk areas that subject Medicare and Medicaid providers to audit and enforcement initiatives. The Work Plan specifically targets skilled nursing facilities (SNFs), hospices, and home health agencies (HHAs). For all types of... READ MORE

Tags: , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , ,

CMS Issues Advance Copy of Long-Term Care Survey Protocol

[10/02/12]

Posted on October 2, 2012 in Long-Term Care, Home Health & Hospice

Written by: Selby, Todd J.

On September 27, 2012, CMS issued an advance copy of the State Operations Manual (“SOM”) revisions to Appendix P of the SOM, which addresses Long-Term Care Facility survey protocol. The SOM guidance also makes changes to various survey forms resulting from the new quality measures reports.

READ MORE

Tags: , , , , , , , , ,