Compliance • Audits/Analysis • Reimbursement/Regulatory • Education/Efficiency
The OIG Work Plan for 2017 is ready for viewing. Below are the top 7 things Nursing Home Providers need to know in order to prepare for the upcoming year. Harmony Healthcare International (HHI) has been guiding you on the process for implementing an effective SNF compliance program over the last 4 years. In addition to completing a facility level Risk Analysis, it is prudent to view the annual OIG Plan for national indicators of the following:
- NEW: Nursing Home Complaint Investigation
Data Brief All nursing home complaints categorized as immediate jeopardy and actual harm must be investigated within a 2-day and 10-day timeframe, respectively. A 2006 OIG report found that State agencies did not investigate some of the most serious complaints within these required timeframes. We will determine to what extent State agencies investigate the most serious nursing home complaints within the required timeframes. This work will provide an update from our previous review.
OEI: 01-16-00330 Expected issue date: FY 2017
- NEW: Skilled Nursing Facilities – Unreported Incidents of Potential Abuse and Neglect
SNFs are institutions that provide skilled nursing care, including rehabilitation and various medical and nursing procedures. Ongoing OIG reviews at other settings indicate the potential for unreported instances of abuse and neglect. We will assess the incidence of abuse and neglect of Medicare beneficiaries receiving treatment in SNFs and determine whether these incidents were properly reported and investigated in accordance with applicable Federal and State requirements. We will also interview State officials to determine if each sampled incident was reported, if required, and whether each reportable incident was investigated and subsequently prosecuted by the State, if appropriate.
OAS: W-00-16-35779 Expected issue date: FY 2017
- NEW: Skilled Nursing Facility Reimbursement
Some SNF patients require total assistance with their activities of daily living and have complex nursing and physical, speech, and occupational therapy needs. SNFs are required to periodically assess their patients using a tool called the Minimum Data Set that helps classify each patient into a resource utilization group for payment. Medicare payment for SNF services varies based on the activities of daily living score and the therapy minutes received by the beneficiary and reported on the Minimum Data Set. The more care and therapy the patient requires, the higher the Medicare payment. Previous OIG work found that SNFs are billing for higher levels of therapy than were provided or were reasonable or necessary. We will review the documentation at selected SNFs to determine if it meets the requirements for each particular resource utilization group.
OAS: W-00-16-35784 Expected issue date: FY 2017
- NEW: Skilled Nursing Facility Adverse Event Screening Tool
OIG developed the SNF adverse event trigger tool as part of its study, "Adverse Events in Skilled Nursing Facilities: National Incidence Among Medicare Beneficiaries" (OEI-06-11-00370), released in February 2014. The tool was developed with assistance from clinicians at the Institute for Healthcare Improvement (IHI), which also published the tool for industry use. This product will describe the purpose, use, and benefits of the SNF adverse event trigger tool and the guidance document released by IHI, including the methodology for developing the instrument and the instrument's use in developing the February 2014 report findings. The product will also describe the contributions of OIG and IHI. The goal of this product is to disseminate practical information about the tool for use by those involved with the skilled nursing industry.
OEI: 06-16-00370 Expected issue date: FY 2017
- REVISED: National Background Checks for Long-Term-Care Employees - Mandatory Review
The ACA provides grants to States, through CMS, to implement background check programs of prospective long-term-care employees and providers. The ACA requires that OIG conduct an evaluation of this grant program, known as the National Background Check Program, after its completion (ACA § 6201). For States that closed their grants in the preceding year, we will review the procedures States implemented for long-term-care facilities and providers to conduct background checks on prospective employees who would have direct access to patients. We will determine the outcomes of the States' programs and whether the checks led to any unintended consequences.
OEI: 07-16-00160 Expected issue date: FY 2017
- Skilled Nursing Facility Prospective Payment System Requirements
Medicare requires a beneficiary to be an inpatient of a hospital for at least 3 consecutive days before being discharged from the hospital to be eligible for SNF services (SSA § 1861(i)). If the beneficiary is subsequently admitted to an SNF, the beneficiary is required to be admitted either within 30 days after discharge from the hospital or within such time as it would be medically appropriate to begin an active course of treatment. Prior OIG reviews found that Medicare payments for SNF services were not compliant with the requirement of a 3-day inpatient hospital stay within 30 days of an SNF admission. We will review compliance with the SNF prospective payment system requirement related to a 3-day qualifying inpatient hospital stay.
OAS: W-00-16-30014 Expected issue date: FY 2017
- Potentially Avoidable Hospitalizations of “Medicare and Medicaid” Eligible Nursing Facility Residents
High occurrences of patient transfers from nursing facilities to hospitals for potentially preventable conditions could indicate poor quality of care. Prior OIG work identified a nursing facility with a high rate of Medicaid recipient transfers to hospitals for a urinary tract infection (UTI), a condition that is often preventable and treatable in the nursing facility setting without requiring hospitalization. The audit disclosed that the nursing facility often did not provide UTI prevention and detection services in accordance with its residents' care plans, increasing the residents' risk for infection and hospitalization. We will review nursing homes with high rates of patient transfers to hospitals for potentially preventable conditions and determine whether the nursing homes provided services to residents in accordance with their care plans (42 CFR § 483.25(d)).
OAS: W-00-17-35792 Expected issue date: FY 2017
Harmony Healthcare International (HHI) is available to provide onsite analysis and associated medical record reviews. Please contact Harmony Healthcare International by clicking here or calling our office at 1.800.530.4413.
6th Annual LTPAC Symposium
Click Here to Review Agenda and Register