Compliance Mentor - August 2015

Hospital Access Management - Hospital Case Management - Hospital Employee Health
Hospital Infection Control - Hospital Peer Review - Healthcare Risk Management
Case Management Advisor - IRB Advisor - Medical Ethics Advisor - Same-Day Surgery

Long-term Care Rules Substantially Revised for the First Time in 24 Years

CMS released proposed rules revising requirements for long-term care (LTC) facilities in July, marking the first substantial change to the CoPs since 1991.

These rules would have to be followed by any LTC facility that accepts Medicare or Medicaid reimbursement. They were drafted to improve patient safety and quality of care for LTC residents and to align with current clinical practice standards. This would impact more than 1.5 million residents in more than 15,000 nursing homes or LTC facilities. Given the significance of these proposed changes, long-term care facilities should immediately focus on their review and how to implement the changes.

The changes include:

• Staff are trained on caring for patients with dementia and in prevention of abuse and neglect
• Staffing needs to take into consideration the type and health of residents they serve
• Improvements in discharge planning
• Improved plans of care and utilizing the interdisciplinary team approach
• Credentialing dieticians to write diet orders in states that permit this
• Requiring nursing homes to provide greater food choices
• Making improvements in the infection control program including the requirement to have an infection preventionist

The proposed changes are published in the July 16, 2015 Federal Register and you can read them here.

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Compliance Guidance for Healthcare Boards

There were a number of organizations that joined together to draft a document called The Practical Guidance for Health Care Boards on Compliance Oversight. It was the first collaboration of its kind between HHS OIG, AHLA, AHIA, and HCCA. It was a joint educational research to assist boards of hospitals and other health care organizations to carry out their compliance oversight responsibilities. Hospital leaders, hospital attorneys, internal auditors and compliance officers should be familiar with this document in addition to board members.

The 19-page document is available at no charge. It has seven chapters that include expectations for board oversight of compliance program functions, roles and relationships, reporting to the board, identifying and auditing potential risk areas, and encouraging accountability and compliance.

The guidance provides advice that boards can adopt in their hospitals. It helps to identify risk and provides a tool to improve the compliance program objectives. It also makes recommendation for effective reporting on compliance issues during board meetings. The document discusses the relationship between internal audit, compliance and legal function of the facility’s compliance program.

There are also a number of other important documents that are available on the OIG’s website.

This includes:

• Handout: A Toolkit for Health Care Boards
• The Healthcare Director’s Compliance Duties; A Continued Focus of Attention and Enforcement
• Driving for Quality in Acute Care: A Board of Directors Dashboard
• Corporate Responsibility and Healthcare Quality- A Resource for Health Care Boards of Directors

A webinar with even more information is available for immediate download here: [On-Demand Webinar] Joint Guidance for Hospital and Health Care Board Compliance or contact customer service for more information at 800-688-2421 or [email protected].

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CMS Proposes Paying for End-of-Life Care Discussion

CMS has proposed to pay physicians and healthcare providers for the time they spend on end-of-life discussions.

This was proposed in the CMS 2016 Medicare physician fee schedule beginning Jan. 1, 2016. The National Academy of Medicine, formerly The Institute of Medicine, made the recommendation in its 2014 document Dying in America. Advance care planning would need to be reasonable and necessary for the diagnosis or treatment of the illness or injury.

There are two advance care-planning codes. These codes provide payment for the time involved in discussing the advance directive issues and in filling out the forms. One code covers the first 30 minutes of discussion while the second covers additional 30 minute blocks of times. CMS estimates the amount would be $86 and $75, respectively.

When final, hospitals may want to ensure their physicians and healthcare providers are familiar with this provision on the end-of-life counseling. It could include short-term treatment options or long-term options, such as considering if patients want a heart transplant if their CHF worsens. More Americans are aging and face advancing chronic health conditions. Advance care planning may help to reduce readmissions by not providing care not desired by terminal patients or getting them into palliative care programs more timely.

Advance directives could include their end-of-life wishes. Advance directives include living wills, DPOAs, organ donor cards, and mental health declarations. To see the original Federal Register article of July 15, 2015, Medicare Program, Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2016, click here.

To learn more about the upcoming webinar on this topic, please click [Live Webinar] Advance Directives Update: What Every Hospital Practitioner Needs to Know or contact us at [email protected] or 800.688.2421 for additional information.

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Updated CMS Hospital CoP Manual: Rewriting Guidelines

Hospitals should be aware that CMS has updated Appendix A. This is the hospital CoP manual. The manual is now 510 pages long and it includes the final changes that basically rewrite all of the radiology and nuclear medicine guidelines. Hospitals should ensure these new interpretive guidelines are shared with radiology and nuclear medicine staff and providers. It makes changes to 13 tag numbers. CMS published a 41-page survey memo discussing these changes on May 15, 2015. The May edition of Compliance Mentor discussed many of the new changes.

The manual can be accessed here and then click on Appendix A.

To learn more about the upcoming webinar on this topic, please click [Live Webinar] New CMS Radiology & Nuclear Medicine Hospital CoPs or contact us at [email protected] or 800.688.2421 for additional information.

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NEW [Webinar] – Live Wednesday, September 23 from 1 - 2 PM ET

Prepare for the Healthcare-Specific Federal OSHA National Emphasis Program

Join Lori A. Severson, CSP as she prepares hospitals and other healthcare facilities for OSHA’s expanded inspection process, announced on June 25^th of this year. Earn 1 nursing contact hour by attending. Click here to order.

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