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Compliance Program Deadline

Deadline Looming for Mandatory Nursing Home Compliance Programs

Skilled Nursing Facilities have until November 28, 2019 to adopt and implement a compliance program that meets the elements set out by the Center for Medicare and Medicaid Services (CMS). Beginning on that date, state survey agencies will start assessing nursing homes’ compliance programs as an additional condition of participation in Medicare and Medicaid. Issued in 2016 as part of CMS’s revised Part 483 of Title 42 (“Requirements for States and Long Term Care Facilities”), the CMS compliance program elements are functionally identical to those from the Office of Inspector General for Health and Human Services (OIG).1 Already the standard for effective compliance programs, the OIG elements are used to measure an organization’s culpability when federal fraud and abuse laws are violated. Specifically, the OIG considers “the existence of an effective compliance program that pre-dated any governmental investigation when addressing the appropriateness of administrative sanctions.”

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Key Implementation Concepts for Drug Regimen Review

Three new items have been added to Section N of the MDS, that will have a major impact on the policies and processes you have used in the past regarding medication reconciliation and administration.

  • N2001: Drug Regimen Review (Assessed on Admission)
  • N2003: Medication Follow-up (Assessed on Admission)
  • N2005: Medication Intervention (Assessed on Discharge)

Although this new item may seem to be commonplace in your facility already, there are scenarios which frequently arise, that may interfere and render your processes inadequate. These fundamental concepts will be required for Medicare Part A covered residents but are considered a best practice for any payer source.

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