Articles and Blogs

The Centers for Medicare & Medicaid Services (“CMS”), in the March 8, 2013 Memorandum, issued new guidance specifying those tasks that can and cannot be delegated in skilled nursing facilities (“SNFs”) and nursing facilities (“NFs”).  Physicians who improperly assign tasks to non-physician practitioners (“NPPs”) jeopardize the SNFs’ and NFs’ compliance with federal and state... READ MORE

The Centers for Medicare & Medicaid Services, in the March 8, 2013 S & C 13-16 NH, revised the Interpretative Guidelines for F-Tag 155 (“Advance Directives”) in Appendix PP of the State Operations Manual.  This memorandum updates S & C 12-47. READ MORE

According to the Centers for Medicare & Medicaid Services (“CMS”), since 1972, there have been in excess of 100 reports of Luer misconnections that have resulted in adverse events.  Recently, a patient’s blood pressure tubing was misconnected to an intravenous line in an ambulatory surgical center (“ASC”) that resulted in the patient’s death.  Generally,... READ MORE

Based on additional feedback, the Centers for Medicare & Medicaid Services (CMS) has revised the surveyor guidance issued in September 2012 on Naso-Gastric Tubes (NG Tubes) for F-Tag F322.  Since the NG Tube regulation, §483.25(g), was published, the use of NG Tubes has become increasingly rare in favor of other forms of enteral feeding... READ MORE

Executive Summary The Office of Inspector General (“OIG”) released a report on March 6 that showed a significant number of Long-Term Care Hospitals (“LTCHs”) that are co-located with skilled nursing facilities (“SNFs”) or acute care hospitals are failing to notify their Medicare Administrative Contractor (“MAC”) or fiscal intermediary (“FI”) of their co-located status. The... READ MORE

McKnight’s published an article this morning on the rise in Carbapenem-Resistant Enterobacteriaceae (CRE) in long-term care facilities.  The Center for Disease Control & Prevention (CDC) states these bacteria kill about half of all people who become infected, and are resistant to antibiotic treatments.  These CRE bacteria are even resistant to the antibiotics “of last resort” and can transfer... READ MORE

The Centers for Medicare & Medicaid Services (CMS) has unofficially announced it will not be enforcing the upcoming March 23rd compliance program requirements until final regulations are published.  As required under the Affordable Care Act, nursing facilities are required to have a compliance program in place by March 23, 2013.  Despite ambiguity in the actual statute,... READ MORE

The Food and Drug Administration (“FDA”) is seeking comments on a draft guidance entitled “Design Considerations for Devices Intended for Home Use.”  The draft guidance urges manufacturers to “design out” product risks and consider usability and training for medical devices intended for use in a home environment.  The deadline for submitting comments on the... READ MORE

In 2003, two fires in long-term care facilities resulted in 31 resident deaths. As a result of these two events, CMS analyzed the fire safety precautions in place in these facilities and determined that resident safety could be greatly improved by requiring that all long-term care facilities have automatic sprinkling systems installed throughout the... READ MORE

The Patient Protection and Affordable Care Act (PPACA) requires all skilled nursing facilities (SNFs) and nursing facilities (NFs) to have an effective compliance and ethics program in place by March 23, 2013.  Unfortunately, the Centers for Medicare & Medicaid Services (CMS) has failed to publish final regulations covering these programs, as required under PPACA, by... READ MORE