Articles and Blogs

Prior to the government shutdown, Representative Jim McDermott of Washington introduced a bill that would end the hospital inpatient requirement for skilled nursing facility (“SNF”) coverage.   READ MORE

One of the main admission requirements for a skilled stay in a skilled nursing facility (“SNF”) is a three-day qualifying stay in an inpatient hospital.  In response to a question discussed on a recent Open Door Forum, the Centers for Medicare & Medicaid Services (“CMS”) released a memorandum discussing if a stay in a... READ MORE

Recently, the Centers for Medicare & Medicaid Services (“CMS”) released the results of a study of hospice general inpatient care (“GIP”) based on an analysis of Medicare Part A hospice claims for beneficiaries who received GIP in 2011.  The intent was to identify suspected abuse of GIP in hospice inpatient facilities by hospice providers because... READ MORE

Executive Summary On March 13, 2013, CMS concurrently released an immediately effective administrative ruling (“CMS Ruling 1455-R” or “Ruling”) and a proposed rule (“Proposed Rule”) reversing CMS policy precluding hospitals from billing on an outpatient basis for inpatient services denied payment on grounds the services should have been provided on an outpatient basis.  Under... READ MORE

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