Articles and Blogs

Long-Term Care, Home Health & Hospice

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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CMS Finalizes New Conditions of Participation for Home Health: Part 6

[02/06/17]

Posted on February 6, 2017 in Health Law News, Long-Term Care, Home Health & Hospice

Published by: Hall Render

Review of the New Home Health Conditions of Participation – Emergency Preparedness, Organization and Administration of Services, Personnel Qualifications and Clinical Records. This is the sixth article in a series discussing CMS’s Final Revised Home Health Conditions of Participation (“Final CoPs”). With the release of the Final CoPs, CMS is finalizing the significant changes they... READ MORE

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CMS Finalizes New Conditions of Participation for Home Health: Part 5

[02/01/17]

Posted on February 1, 2017 in Health Law News, Long-Term Care, Home Health & Hospice

Published by: Hall Render

Review of the New Home Health Conditions of Participation – Patient Rights (part 2). This is the fifth article in a series discussing CMS’s Final Revised Home Health Conditions of Participation (“Final CoPs”). With the release of the Final CoPs, CMS is finalizing the significant changes they proposed to make to the home health... READ MORE

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CMS Finalizes New Conditions of Participation for Home Health: Part 4

[01/30/17]

Posted on January 30, 2017 in Health Law News, Long-Term Care, Home Health & Hospice

Published by: Hall Render

Review of the New Home Health Conditions of Participation – Patient Rights. This is the fourth article in a series discussing CMS’s Final Revised Home Health Conditions of Participation (“Final CoPs”). With the release of the Final CoPs, CMS is finalizing the significant changes they proposed to make to the home health CoPs in... READ MORE

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CMS Finalizes New Conditions of Participation for Home Health: Part 3

[01/26/17]

Posted on January 26, 2017 in Health Law News, Long-Term Care, Home Health & Hospice

Published by: Hall Render

Review of the New Home Health Conditions of Participation – Infection Control and Prevention; Skilled Professional Services; and Home Health Aide Services. This is the third article in a series discussing CMS’s Final Revised Home Health Conditions of Participation (“Final CoPs”). With the release of the Final CoPs, CMS is finalizing the significant changes... READ MORE

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CMS Finalizes New Conditions of Participation for Home Health: Part 2

[01/20/17]

Posted on January 20, 2017 in Health Law News, Long-Term Care, Home Health & Hospice

Published by: Hall Render

Review of the New Home Health Conditions of Participation – Release of Patient Identifiable OASIS information, Reporting OASIS Information and Comprehensive Assessment of Patients; and Care Planning, Coordination of Services and Quality of Care. This is the second article in a series discussing CMS’s Final Revised Home Health Conditions of Participation (“Final CoPs”). With... READ MORE

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CMS Finalizes New Conditions of Participation for Home Health: Part 1

[01/17/17]

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

Published by: Hall Render

Review of the New Quality Assessment and Performance Improvement Condition This is the first article in a series discussing CMS’s pre-publication copy of the Final Revised Home Health Conditions of Participation (“Final CoPs”). With the release of the Final CoPs, CMS is finalizing, with only a few changes, the significant changes they proposed to... READ MORE

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After More Than Two Years, CMS Releases Final Home Health CoPs

[01/10/17]

Posted on January 10, 2017 in Health Law News, Long-Term Care, Home Health & Hospice

Published by: Hall Render

This time things are really going to change. On January 9, 2017, the Centers for Medicare & Medicaid Services (“CMS”) released a pre-publication copy of the Final Revised Home Health Conditions of Participation (“Final CoPs”). With the release of the Final CoPs, CMS is finalizing, with only a few changes, the significant changes they proposed to... READ MORE

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CMS Issues Guidance Suspending Enforcement of Rule Prohibiting Use of Pre-Dispute Binding Arbitration Agreements While Court Ordered Injunction Remains in Effect

[12/19/16]

Posted on December 19, 2016 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