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Staff Training and Policy Reviews Needed: OIG Finds Skilled Nursing Facilities Failing to Report and Investigate Incidents of Potential Abuse and Neglect

[06/14/19]

Posted on June 14, 2019 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

Most skilled nursing facilities and state survey agencies are not correctly reporting and investigating abuse and neglect incidents that occur against skilled nursing residents, according to the June 7, 2019, Office of the Inspector General (“OIG”) of the U.S. Department of Health and Human Services report titled Incidents of Potential Abuse and Neglect at Skilled Nursing... READ MORE

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Graduate Medical Education: Insights About the 2020 IPPS Proposed Rule and Medical Record Documentation

[06/11/19]

Posted on June 11, 2019 in Health Law News

Published by: Hall Render

The Centers for Medicare & Medicaid Services (“CMS”) recently made several announcements regarding graduate medical education (“GME”). This article discusses three matters that are particularly significant for teaching hospitals, teaching physicians and other GME stakeholders. First, CMS issued its inpatient prospective payment system (“IPPS”) proposed rule (“Proposed Rule”) for fiscal year 2020 and announced... READ MORE

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Countdown to Phase 3 Skilled Nursing Compliance Programs – Component #5 – Effective Communication of Compliance Standards to Staff, Contractors and Volunteers

[06/10/19]

Posted on June 10, 2019 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”). To view other articles in this series, click here. Beginning on November 28,... READ MORE

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Countdown to Phase 3 Skilled Nursing Compliance Programs – Component #4 – Screening Process for Positions With Discretionary Authority

[06/06/19]

Posted on June 6, 2019 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”). To view other articles in this series, click here. Beginning on November 28,... READ MORE

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CMS Finalizes New Regulations for Program of All-Inclusive Care for the Elderly (PACE) Organizations

[06/04/19]

Posted on June 4, 2019 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

On June 3, 2019, the Centers for Medicare & Medicaid Services (“CMS”) published revisions and updates to Part 460 to Title 42 of the Code of Federal Regulations. The requirements for the Programs of All-Inclusive Care for the Elderly (“PACE”) under the Medicare and Medicaid programs (“Final Regulations”) cover many regulatory requirements for PACE... READ MORE

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Countdown to Phase 3 Skilled Nursing Compliance Programs – Component #3 – Sufficient Resources and Authority

[05/29/19]

Posted on May 29, 2019 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”). To view other articles in this series, click here. Beginning on November 28,... READ MORE

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Countdown to Phase 3 Skilled Nursing Compliance Programs – Component #2 – Assign Oversight Responsibility of Compliance Program

[05/22/19]

Posted on May 22, 2019 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”). To view other articles in this series, click here. Beginning on November... READ MORE

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CMS Releases FFY 2021 Preliminary Public Use File and Wage Index Development Timetable

[05/22/19]

Posted on May 22, 2019 in Health Law News

Published by: Hall Render

On May 17, 2019, CMS released the preliminary FY 2021 Worksheet S-3, Parts II and III wage index Public Use File (“PUF”). The PUF contains wage data based on FFY 2017 hospital cost reports – that is, cost reports with fiscal year begin dates of on or after October 1, 2016 and on or before September 30, 2017. The... READ MORE

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GAO Lab Report – Sound Analysis? Criticism from Senator Grassley and Others and CMS’s Response

[05/20/19]

Posted on May 20, 2019 in Health Law News

Published by: Hall Render

In November 2018, the Government Accountability Office (“GAO”) released a report (“Report”) on new laboratory payment rates established by CMS under the Protecting Access to Medicare Act (“PAMA”). In the Report, the GAO analyzed Medicare claims data to assess how CMS’s implementation of these new rates will impact Medicare expenditures and recommended CMS take... READ MORE

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DOJ Self-Disclosure and Cooperation Credit

[05/17/19]

Posted on May 17, 2019 in False Claims Act Defense

Published by: Hall Render

The DOJ’s recent revisions to its Justice Manual created a new path for self-disclosing potential fraud to the government – one which is unique in its ability to defray the costs of potential False Claims Act violations. In 2015, Deputy Attorney General Sally Quillian Yates released a memo entitled Individual Accountability for Corporate Wrongdoing, more... READ MORE

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