Harmony Healthcare Blog

Requirements of Participation (CMS): Phases 1,2,3 Checklist

Posted by Kris Mastrangelo on Tue, Nov 01, 2016


Compliance • Audits/Analysis • Reimbursement/Regulatory • Education/Efficiency

Harmony Healthcare International (HHI) is honored to serve the SNF Industry during these complex, unpredictable (watch the news and election drama) and fast past times.  We are hopeful that the following checklist of the recently published Requirements of Participation is helpful.  We outlined the areas due within each phase.  This is to give you a “birds-eye” view of what you and your staff must prepare for over the next three years.  A more detailed check list to follow, however, in the meantime, it is important to gain an understanding of the broad scope necessary for success. 

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Topics: CMS, Requirements of Participation

Are You Survey Ready? Federal Remedies Soon Approaching

Posted by Kris Mastrangelo on Thu, Aug 18, 2016


Compliance • Audits/Analysis • Reimbursement/Regulatory • Education/Efficiency

In July 2016, the Centers for Medicare and Medicaid Services issued a memorandum on the mandatory imposition of federal remedies and assessment factors used to determine the seriousness of deficiencies for nursing homes. 

Skilled Nursing Facilities, Nursing Facilities, and dually participating facilities are required to be in compliance with Medicare and Medicaid guidelines. Facilities have a responsibility to correct any deficiencies identified at the time of a Federal Survey in order avoid penalty, including termination of the provider agreement. CMS and State Survey agencies have no obligation to allow non-compliant facilities an opportunity to correct deficiencies prior to imposing federal enforcement remedies which include but are not limited to civil money penalties, directed plan of correction and temporary management. 

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Topics: CMS, Deficiencies, Federal Remedies

Is it Too Late to Prepare for SNF Quality Reporting?

Posted by The Harmony Team on Thu, Jul 14, 2016

Did you hear what CMS said? One of the big nuggets derived from the CMS SNF Quality Reporting call conducted July 12th was that payment for FY 2017 will be based on data collected between October 1, 2016 – December 31, 2016.  Yes, you are reading this correctly, you have approximately two months to get your ducks in a row with your QMs to stay ahead of the curve for your anticipated reimbursement for FY 2017.  This may not be new information for you or your team, yet the time is nearing when MDS data and claims data culled from your facility will impact your facility’s future payment rates. The overview provided by CMS during the call detailed some key points from the IMPACT Act for applicable PAC settings. The speakers discussed the SNF Quality Reporting Program with regards to the PPS FY2016 Final Rule.

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Topics: Final Rule, CMS, IMPACT Act, SNF Quality Reporting

CMS Releases Skilled Nursing Utilization and Payment Public Use File

Posted by The Harmony Team on Wed, Mar 30, 2016

On March 9, 2016, The Centers for Medicare and Medicaid Services (CMS) announced the release of their public data set called the Skilled Nursing Facility Utilization and Payment Public Use File (PUF).  This report is released as part of the Administration's efforts to make the healthcare system more transparent, affordable and accountable.  The Skilled Nursing Facility PUF contains information on utilization, payment, and submitted charges and is organized by the CMS Certification Number, Resource Utilization Group (RUG) and state of service.  The recently released report contains information about calendar year 2013.  CMS acknowledges that this data has limitations, as it does not address the quality of care provided by individual Skilled Nursing Facilities.  The report contains only utilization information and the data is not risk adjusted to account for differences in the underlying severity of diseases of patient populations treated by providers.

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Topics: CMS, RUGs, Payment Public Use File, PUF

CMS Initiates Pilot of Infection Assessment & Prevention Improvement Surveys

Posted by The Harmony Team on Mon, Feb 29, 2016

With a heightened focus on the growing issues with infection, specifically the Ebola Virus, The Centers for Medicare and Medicaid Services has teamed up with the Centers for Disease Control and Prevention (CDC) to begin a process of providing surveys and education across the healthcare continuum.  The intent of this process is to assist the industry with identifying issues with infection control practices and develop procedures to assist with prevention of cross contamination and the spread of disease. The initial primary focus of this plan will be nursing facilities and hospitals. CMS offered the following summary in a recent press release.

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Topics: CMS, Survey, Infection Prevention, Infections

Medicare Advantage Organization HIPPS Codes Update

Posted by Kris Mastrangelo on Mon, Jul 07, 2014

Clarification is in order. Originally, when billing for all Medicare Advantage Organizations (MAO), PACE Organizations, Cost Plans, and certain demonstration projects, providers were originally told by CMS that they must provide Health Insurance Prospective Payment System (HIPPS) Codes for Skilled Nursing Facility (SNF) claims submitted effective July 1, 2014. This left Skilled Nursing Facility providers concerned that they would then be required to follow the traditional Medicare PPS schedule in order to accurately provide HIPPS codes for billing.  On May 23, 2014, CMS released a memo regarding Submission of Health Insurance Prospective Payment System (HIPPS) Codes to the Encounter Data System to all MAO providers clarifying the requirements.

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Topics: CMS, Managed Care, MDS Coding

Centers for Medicare and Medicaid Services (CMS) Proposed Rule FY2015

Posted by Kris Mastrangelo on Mon, Jun 09, 2014

CMS Proposed Rule FY2015:  On May 6,2014, the Centers for Medicare and Medicaid Services (CMS) issued a Proposed Rule [CMS-1605-P] under the Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities. The Proposed Rule illustrates the proposed Fiscal Year 2015 Medicare payment rates for skilled nursing facilities (SNFs).  The Proposed Rule outlines an estimated increase in SNF payments of 2.0%.  This estimated increase is attributable to the 2.4% market basket increase, reduced by the 0.4% point multifactor productivity adjustment required by law.  As the actual amount of change in the market basket index at -0.3 did not exceed the 0.5 percentage point threshold, the payment rates for FY2015 do not include a forecast error adjustment. 

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Topics: Final Rule, Medicare, CMS, OIG, PPS, Skilled Nursing Facility

Medicare Rehabilitation Medium and Low RUG Categories - Distinct Days

Posted by Kris Mastrangelo on Tue, Dec 10, 2013

CMS released the Final Rule in August 2013 solidifying the changes to the calculation for classification into the Medicare Rehabilitation Medium and Low RUG categories for RUG-IV. The changes began with assessment dates with an ARD on or after October 1, 2013.

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Topics: CMS, MDS 3.0, RUG-IV;

Medicare & Medicaid Integrity Issues: Who Is Auditing Us Now?

Posted by The Harmony Team on Wed, Aug 28, 2013

In the ever changing world of Medicare review contractors, it can be hard to tell who’s auditing us now.  New Program Safeguard Contractors (PSCs) are continually being developed while others fall to the side.  To help keep you up to speed, here is some background information along with a recent update from CMS Program Integrity. 

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Topics: CMS, Denial Management

Quality Assurance and Performance Improvement (QAPI)

Posted by The Harmony Team on Wed, Aug 21, 2013

CMS is undertaking a bold initiative to broaden quality assurance and performance improvement activities (QAPI) in nursing homes.  In March 2010, Congress passed the Affordable Care Act. The Provisions set forth significantly expand the level and scope of required QAPI activities to ensure that facilities continuously identify and correct quality deficiencies as well as sustain performance improvement. The new QAPI regulations will include the requirement that all homes must submit to the Secretary a plan for the facility to meet QAPI standards and implement QAPI best practices, including how to coordinate the implementation of a QAPI plan with QAA activities conducted under existing regulations.

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Topics: CMS, QAPI

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