Compliance Mentor - February 2016

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

The Joint Commission Releases Standards on Antibiotic Stewardship

Antibiotics, when used as indicated, can save lives in the hospital setting. However, antibiotic misuse and overuse are contributing to the problem of antibiotic-resistant infections and serious side effects such as Clostridium difficile. Hospitals that have antibiotic stewardship programs and follow guidelines in resources such as the CMS infection control worksheet can reduce unnecessary antibiotic usage and side effects.

To further the cause of antibiotic stewardship, The Joint Commission has released a set of draft standards in the December issue of its Perspectives newsletter. The standards would apply to all hospitals, nursing care centers, and office-based surgery practices. The standards can be found in The Joint Commission Perspectives, December 2015, Volume 35, Number 12, at http://www.jcrinc.com/the-joint-commission-perspectives/.

Other antibiotic stewardship resources include the following:

• The Joint Commission also has a free antibiotic stewardship toolkit at http://www.jcrinc.com/antimicrobial-stewardship-toolkit/.
• The American Hospital Association toolkit is located at http://www.ahaphysicianforum.org/resources/appropriate-use/antimicrobial/ASP-Toolkit-v3.pdf.
• The CDC’s core elements for antibiotic stewardship programs for long-term care facilities can be found at http://www.cdc.gov/longtermcare/prevention/antibiotic-stewardship.html.
• The CDC’s core elements of hospital antibiotic stewardship programs can be found at http://www.cdc.gov/getsmart/healthcare/implementation/core-elements.html, and the checklist at http://www.cdc.gov/getsmart/healthcare/pdfs/checklist.pdf.

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Study: Lifting ICU Visitation Restrictions Improves Family Satisfaction

A recent article published in the American Journal of Critical Care found that eliminating visitation restrictions to the ICU improved family satisfaction. The authors noted that many ICUs continue to restrict visitation. The study authors suggested replacing ICU visitation restrictions with a policy that is limited solely by the patient’s preference and clinical status. Nurses in hospitals with such policies noted positive visitor satisfaction and reported no decrease in nursing satisfaction.

Visitation plays an important role in the care of hospital patients. In December 2011, CMS added 32 pages of visitation standards to its hospital Conditions of Participation that recommend open visitation in the ICU and critical care units – a quality initiative also taken by the Institute for Healthcare Improvement. Both CMS and IHI found that open visitation hours did not cause physiologic stress for patients, barriers to the provision of care, nor exhaustion for family or friends.

The current CMS hospital CoP manual, November 20, 2015, is available at https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/som107_Appendixtoc.pdf and starts at tag number 215.

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Recovery Audit Program Update: Decreasing the Amount of Hospital Claims

The Recovery Audit Contractors (RACs) identify, correct, and collect Medicare payments improperly paid to providers. The RAC program was created through a federal law known as the Medicare Modernization Act of 2003 (MMA). It was originally a three-year demonstration project that was made permanent by the Tax Relief and Health Care Act of 2006. The program was scaled back in January 2016, with RACs only able to audit 0.5% of hospital claims within a 45-day period -- down from the original 2% -- and will no longer audit records going back three years.

This may come as a relief for hospitals that have felt financial and administrative burdens due to RAC audits. The American Hospital Association and other healthcare organizations have lobbied for changes to the RAC program. Some hospitals reported having spent hundreds of thousands of dollars in appeals, audits, and denials from the program.

To read more about the RAC program, please visit the CMS website at https://www.cms.gov/research-statistics-data-and-systems/monitoring-programs/medicare-ffs-compliance-programs/recovery-audit-program/.

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OIG 2016 Work Plan Focuses on Medicare Part D Sponsor Compliance

The Office of Inspector General (OIG) has released its 80-page work plan for 2016. The work plan describes various projects that are being addressed by the Office of Audit Services, Office of Evaluation and Inspections, Office of Investigations, and Office of Counsel to the Inspector General.

This year, the work plan summarizes new and ongoing reviews, with new focus areas regarding Medicare Part D pharmacy sponsor compliance. A report is expected to be published in 2017 that will address how pharmacies determine beneficiary eligibility in the Part D program. The OIG is also looking at Part B claims for orthopedic braces to determine medical necessity. Other topics include target specialty drugs, Medicare drug utilization review, chiropractic claims, hospital claims, billing, payments, reconciliation of outlier payments, admissions, the two-midnight rule, oversight of provider-based facilities, and more.

To view a copy of the OIG’s 2016 work plan, please visit http://oig.hhs.gov/reports-and-publications/archives/workplan/2016/oig-work-plan-2016.pdf.

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