Articles and Blogs

Long-Term Care, Home Health & Hospice

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

[09/06/18]

Posted on September 6, 2018 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

On January 13, 2017, CMS published the revised Conditions of Participation (“CoPs”) for home health agencies, 42 CFR 484, Subparts A, B, and Subpart C. The CoPs became effective on January 13, 2018. On August 31, 2018, the Centers for Medicare & Medicaid Services (“CMS”) issued a Memorandum to State Survey Agency Directors (QSO-18-25-HHA) that... READ MORE

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CMS Adds Survey Process for Reviewing Home Dialysis Services in Long-Term Care Facilities

[08/28/18]

Posted on August 28, 2018 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

On August 17, 2018, the Centers for Medicare & Medicaid Services (“CMS”) issued a Memorandum to State Survey Agency Directors (QSO-18-24-ESRD) outlining additional survey activities that address dialysis services provided by an end-stage renal disease (“ESRD”) facility to residents in a long-term care facility. The survey process for evaluating home dialysis in nursing homes consists... READ MORE

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CMS Issues Final Rule on FY 2019 Payment and Policy Changes for Skilled Nursing Facilities

[08/07/18]

Posted on August 7, 2018 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

On July 31, 2018, the Centers for Medicare & Medicaid Services (“CMS”) issued a final rule (CMS-1696-F) outlining Fiscal Year (“FY”) 2019 Medicare payment updates and quality program changes for skilled nursing facilities (“SNF”)(“Final Rule”). The Final Rule finalized the value-based purchasing payments that start October 1, 2018, updated several SNF Quality Reporting Program... READ MORE

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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 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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