Articles and Blogs

The future of post-acute provider enforcement actions will likely include increased attention, investigation and citing of infection control practices and resident abuse and neglect. On August 31, 2020, the Office of Management and Budget issued a Memorandum for the Deputy Secretaries of Executive Departments and Agencies (M‑20-31) titled “Implementation of Section 6 of Executive... READ MORE

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

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

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