Articles and Blogs

Conditions of Participation

Do SNFs, HHAs and Hospice Providers Need Individual Section 1135 Waivers for COVID-19 Activities?

[03/20/20]

Posted on March 20, 2020 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

On March 13, 2020, Secretary Azar of the Department of Health and Human Services (the “HHS”) issued a letter titled “Waiver or Modification of Requirements Under Section 1135 of the Social Security Act” (the “Azar Letter”) that grants the Centers for Medicare & Medicaid Services (the “CMS”) the authority to issue waivers specific to... READ MORE

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COVID-19 Guidance for Home Health Agencies

[03/18/20]

Posted on March 18, 2020 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

On March 10, 2020, the Quality, Safety & Oversight Group at the Centers for Medicare & Medicaid Services (“CMS”) issued a memorandum entitled “Guidance for Infection Control and Prevention Concerning Coronavirus Disease 2019 (“COVID-19”) in Home Health Agencies (“HHAs”)” (“QSO Memo”) that announced recommendations for HHAs regarding taking appropriate action to address potential and confirmed COVID-19... READ MORE

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CMS Offers COVID-19 Guidance and Flexibility to PACE Programs

[03/18/20]

Posted on March 18, 2020 in Long-Term Care, Home Health & Hospice

Written by: Fahey, Sean J.

On March 17, 2020, the Centers for Medicare & Medicaid Services (“CMS”) issued a memorandum titled “Information for PACE Organizations Regarding Infection Control and Prevention of Coronavirus Disease 2019 (COVID-19)” (“CMS Memo”) that announced COVID‑19 guidance for Programs of All-Inclusive Care for the Elderly (“PACE”) program organizations (“PACE Organization”). The PACE program is a... READ MORE

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Hall Render’s This Week in Washington – September 21, 2018

[09/21/18]

Posted on September 21, 2018 in Federal Advocacy

Published by: Hall Render

Hospitals Release Voluntary 340B Principles as Alternative to Legislation The battle over 340B continued this week as hospital groups announced a new voluntary 340B reporting program as an alternative to congressional legislation that would further regulate the program. Under the American Hospital Association-led initiative, hospitals would commit to publicly disclosing their 340B savings annually.... READ MORE

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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 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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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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