Articles and Blogs

After October 31, 2011, DMEPOS suppliers will no longer be permitted to use the 07/09 version of the CMS-855S application and will be required to utilize the updated 07/11 version. The 07/11 version is available and may be used for submissions now. The newest version of the application has been updated to capture additional... READ MORE

The NLRB announced last week that it has postponed the implementation date for its new notice-posting rule (previously discussed here and here) by more than two months in order to allow for “enhanced education and outreach to employers”, particularly those who operate small and medium sized businesses.  The posting requirement for most private employers... READ MORE

McKight’s points to a recent study that suggests nursing uniforms laundered at home have not been adequately sanitized.  The study from the University College in London found residential washing machines only heated water to 104 degrees Fahrenheit, leaving substantial amounts of bacteria behind. Investigators found that thorough ironing after washing was successful in removing remaining Acinetobacter... READ MORE

Effective October 1, new PPS rules for fiscal year 2012 require nursing homes to diligently review claims prior to submission.  As previously discussed, significant cuts in SNF reimbursement are aimed mostly at therapy services.   SNFs submitting claims under the previous rules can expect high rates of denials and rejections.  Even facilities billing under the new... READ MORE

CMS has published a proposed regulation that would limit the ability of institutional pharmacies to offer pharmacist consultation services to facilities.  CMS believes that relationships between nursing homes and pharmacy suppliers could result in “recommendations that conflict with the best interests of nursing home residents.” The proposed regulation would require facilities to hire independent pharmacists to... READ MORE

CMS will host their monthly Skilled Nursing/LTC Open Door Forum on Thursday, October 20, from 2-3pm EST.  This call was originally scheduled on October 13.  The information to participate in the call is available here. The recent changes to MDS 3.0 and PPS are likely to be heavily discussed topics.    Should you have any questions, please contact: Todd Selby... READ MORE

On October 5, 2011, the National Labor Relations Board announced that it has postponed the implementation date for its new Notice Posting Rule by more than two months in order to allow for “enhanced education and outreach to employers,” particularly those who operate small and medium sized businesses.  The posting requirement for most private... READ MORE

Executive Summary On October 5, 2011, the Office of Inspector General (“OIG”) published its proposed Work Plan for Fiscal Year (“FY”) 2012 (“Plan”).  The Plan, which is published annually and describes the OIG’s new and ongoing audit and enforcement priorities for the upcoming year, is helpful in identifying corporate compliance risk areas and providing... READ MORE

The Centers for Medicare and Medicaid Services (“CMS”) released a final rule modifying the Medicare Electronic Prescribing Incentive Program (“eRx Program”) on August 31, 2011.  The eRx Program provides an incentive to “Eligible Professionals” who adopt e-prescribing technology beginning in 2009 and a payment adjustment (or penalty) for late adopters beginning in 2012.  The... READ MORE

A good reminder for leases between health care entities and physician groups is that under the Stark regulations, the space rented is reasonable and necessary for the legitimate business purposes of the lease and is used exclusively by the lessee (during such times when the lessee is using the space) and is not shared... READ MORE