Articles and Blogs

Skilled nursing facilities (“SNFs”) are facing many challenges as they reopen their communities to visitors. State health departments are issuing guidance on outdoor SNF visits and phased reopening of businesses. On June 24, 2020, CMS released visitor guidance in the form of several pages of FAQs “Frequently Asked Questions (FAQs) on Nursing Home Visitation”... READ MORE

Skilled nursing facilities (“SNFs”) are facing many challenges as their residents and staff encounter COVID-19. During the COVID-19 pandemic, Centers for Medicare & Medicaid Services (“CMS”) and state departments of health have focused on infection control surveys, programs, and prevention. This week, the Centers for Disease Control and Prevention, Center for Preparedness and Response... READ MORE

Skilled nursing facilities (“SNFs”) are facing many challenges as their residents and staff encounter COVID-19 diagnosis, care and testing. During the COVID-19 pandemic, CMS and state departments of health have issued and revised interim final regulations, waivers, quality care directives, orders and multiple guidance memos. In early June 2020, the U.S. Department of Justice... READ MORE

The Department of Health and Human Services (“HHS”) updated its Provider Relief Fund Frequently Asked Questions (“FAQs”). The latest revisions are dated May 26 and 29, 2020 and June 2, 2020 and include new FAQs and modifications to existing FAQs. A Hall Render alert on those revisions and updates is here. HHS added FAQs... READ MORE

The transfers and discharges of COVID-19 positive and COVID-19 negative residents are challenging for skilled nursing facilities (“SNFs”) and/or nursing facilities (“NFs”), (in this alert, SNFs and NFs are collectively Long‑Term Care Facilities “LTC Facilities”) as they navigate the evolving government guidance and delicate communication and public relations areas. On April 13, 2020, the... READ MORE

On March 23, 2020, Centers for Medicare & Medicaid Services (“CMS”) announced the preliminary results of a recent survey of a nursing home in Kirkland, Washington, the epicenter of the COVID-19 outbreak in Washington. According to a Centers for Disease Control and Prevention (“CDC”) report, 81 residents, 34 staff and 14 visitors also became... READ MORE

On March 13, 2020, Secretary Azar of the Department of Health and Human Services (the “HHS”) issued a letter titled “Waiver or Modification of Requirements Under Section 1135 of the Social Security Act” (the “Azar Letter”) that grants the Centers for Medicare & Medicaid Services (the “CMS”) the authority to issue waivers specific to... READ MORE

Summary In a February 2019 report, No. A-01-17-00506, HHS Office of the Inspector General (“OIG”) determined that Medicare made Part B payments to ambulance suppliers for transportation services that were covered through the Medicare Part A payments to skilled nursing facilities (“SNF”) as part of consolidated billing requirements. With certain exceptions, the SNF Part... READ MORE

On July 22, 2016, the Center for Clinical Standards and Quality/Survey & Certification Group released a memorandum that revised Chapter 7 of the State Operations Manual (“SOM”) and provided guidance on its policy to immediately impose federal remedies when a deficiency of a certain type is cited. The remedies are in addition to a... READ MORE

Subject to various exceptions, a covered skilled nursing facility (“SNF”) stay must initiate within 30 days of a qualifying hospital stay.  In some cases where it is medically predictable that an individual will require a covered level of SNF care within a determinable time frame, that same individual may also have a need for a covered... READ MORE