Articles and Blogs


Countdown to Phase II Compliance: The Facility Assessment for Long-Term Care Facilities – Review of Facility Resident Population and Resources Required


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


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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Massive Penalty Spike Darkens the FCA Landscape


Posted on June 30, 2016 in False Claims Act Defense

Written by: David B. Honig

In November 2015, the Bipartisan Budget Act of 2015 went into effect. One aspect of that act was the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. The new law required that the Program Fraud Civil Remedies Act and the False Claims Act (“FCA”) penalties be “corrected” to adjust for inflation since... READ MORE

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