Articles and Blogs

Representative John Kline of Minnesota introduced the Workforce Democracy and Fairness Act last week in response to recent NLRB actions affecting employers.  One aspect of this Bill is the reversal of the NLRB’s Specialty Healthcare decision which altered the established standard for determining collective bargaining units in non-acute care health facilities.    READ MORE

As previously discussed, hospice providers are required to have a hospice physician or nurse practitioner perform a face-to-face encounter with each hospice patient whose total length of stay is anticipated to reach the third benefit period.  This encounter must be performed no more than thirty days prior to the third benefit period recertification, and... READ MORE

On October 5, 2011, the Office of Inspector General (OIG) published its proposed Work Plan for Fiscal Year 2012. As in the past, the Work Plan continues to identify compliance risk areas that subject Medicare and Medicaid providers to audit and enforcement initiatives. The 2012 Work Plan contains several new areas of focus by... READ MORE

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 September 23, 2011, the Department of Health and Human Services (DHHS) Centers for Medicare & Medicaid Services (CMS) published the initial release of the Medicaid Program Integrity Manual.  The new Manual is designed to encourage continuity and consistency within the Medicaid Integrity Program (MIP) by providing a comprehensive guide to MIP’s operations.  The... READ MORE