Articles and Blogs

hha

Caution – Pay No Mind to the Department of Labor’s Temporary Non-Enforcement Policy Relating to the Companion Services Exemption

[10/31/14]

Posted on October 31, 2014 in Long-Term Care, Home Health & Hospice

Written by: Taylor, Allison L.

In the October 9, 2014 Federal Register, the Department of Labor (“DOL”) indicated it will delay enforcement of the Companion Services Rule (“Rule”) until June 30, 2015 (the “Notice”). The DOL suggests this delayed enforcement is meant to assist the provider community with implementing changes in the Rule. In its commentary, the DOL suggests... READ MORE

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Obama Budget Contains Numerous Post-Acute Care Cuts

[03/05/14]

Posted on March 5, 2014 in Long-Term Care, Home Health & Hospice

Written by: Selby, Todd J.

President Obama introduced his fiscal year (“FY”) 2015 budget yesterday, and there are many proposed cuts to post-acute care providers.  Some of the highlights include a number of bundled payment initiatives, a $100 co-pay for home health patients not discharged from a hospital and re-admission penalties for skilled nursing facilities (“SNFs”) with high hospital... READ MORE

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Rebasing Has Arrived – CMS Publishes Home Health PPS 2014 Proposed Rule

[07/02/13]

Posted on July 2, 2013 in Long-Term Care, Home Health & Hospice

Written by: Robert W. Markette

On June 27, 2013, CMS released the proposed home health prospective payment rule (the “PPS Rule”) for calendar year 2014.  While refinements to the ICD-9-CM and discussions of ICD-10-CM implementation are of interest, the most notable change to the PPS Rule for 2014 is CMS’s long-awaited proposal for rebasing home health payments.  Once it... READ MORE

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CMS Revises Policy as to Surveys to Be Conducted Following Complaint Investigations Resulting in Condition-Level Noncompliance

[04/26/13]

Posted on April 26, 2013 in Long-Term Care, Home Health & Hospice

Written by: Bufford, David W.

The Centers for Medicare & Medicaid Services (“CMS”) recently released a Survey and Certification Letter updating the State Operations Manual (“SOM”) guidelines  on surveys of deemed status long-term care (“LTC”) providers when the provider has been found to have a condition level instance of noncompliance, including immediate jeopardy (“IJ”), in a complaint survey.  This change... READ MORE

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Sequestration Cuts Impact Nursing Homes and Post-Acute Care Providers

[04/10/13]

Posted on April 10, 2013 in Long-Term Care, Home Health & Hospice

Written by: Selby, Todd J.

In a transmittal issued on April 5, 2013, CMS provided guidance on survey activities that will be affected by the sequestration cuts.  The transmittal provides guidance on several areas that will have an immediate and potentially negative effect on nursing homes and post-acute care providers.  These changes will affect the survey process as conducted by the state survey... READ MORE

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MedPAC Releases Report to Congress, Suggests Broad Reforms to Post-Acute Landscape

[03/18/13]

Posted on March 18, 2013 in Long-Term Care, Home Health & Hospice

Written by: Bufford, David W.

The Medicare Payment Advisory Commission’s (“MedPAC”) March 25th Report to Congress outlines inefficiencies they believe exist in the post-acute world and lead to excessive Medicare payments to providers. MedPAC recommendations include Congress evaluate post-acute provider reimbursement and encourage use of the lowest cost mix of services necessary to achieve the best outcomes. READ MORE

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OIG Publishes 2013 Work Plan

[10/05/12]

Posted on October 5, 2012 in Long-Term Care, Home Health & Hospice

Written by: Bufford, David W.

The Office of the Inspector General (OIG) has published their annual Work Plan for 2013. The Work Plan continues to identify compliance risk areas that subject Medicare and Medicaid providers to audit and enforcement initiatives. The Work Plan specifically targets skilled nursing facilities (SNFs), hospices, and home health agencies (HHAs). For all types of... READ MORE

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Inappropriate and Questionable Billing by Medicare Home Health Agencies

[08/02/12]

Posted on August 2, 2012 in Long-Term Care, Home Health & Hospice

Written by: Selby, Todd J.

Data collected and analyzed by the Office of Inspector General (OIG) since 2010, indicate that home health agencies (HHAs) are predisposed to commit Medicare fraud, waste and abuse. In 2010, Medicare inappropriately paid $5 million for erroneous claims submitted by HHAs. With one in four claims being suspect, the OIG established six (6) criteria... READ MORE

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Home Health Agencies’ Claims for Ordered/Referred Services Must be Billed Using Individual Physician’s Name and NPI

[07/24/12]

Posted on July 24, 2012 in Long-Term Care, Home Health & Hospice

Written by: Selby, Todd J.

In the near future, Regional Home Health Intermediaries (RHHIs) and Parts A and B Medicare Administrative Contractors (A/B MACs) will be contacting home health agencies (HHAs) that have previously submitted claims for ordered or referred services using a group name and national provider identifier (NPI).  HHAs will be informed they should begin submitting such... READ MORE

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CMS Releases 2012 Nursing Home Action Plan

[07/06/12]

Posted on July 6, 2012 in Long-Term Care, Home Health & Hospice

Written by: Bufford, David W.

The Centers for Medicare & Medicaid Services (CMS) just released the 2012 Nursing Home Action Plan; a guide for CMS’ efforts to continue to improve nursing home safety and quality.  The plan features 5 actionable strategies, including: enhance consumer engagement; strengthen survey processes, standards, and enforcement; promote quality improvement; create strategic approaches through partnerships; and... READ MORE

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