Nursing home plan focuses on quality-of-care issues

The Department of Health and Human Services’ Office of Inspector General (OIG) released its final compliance plan for nursing homes earlier this month. Experts say the final plan includes mostly subtle changes from the draft, which introduced a heavy emphasis on quality-of-care issues.

Howard Sollins of the Baltimore-based Ober Kaler, says long-term care providers should pay close attention to the government’s increased scrutiny of those quality-of-care issues. "The guidance highlights the agency’s major focus on quality of care and its relationship to regulatory compliance," he asserts. "Especially noteworthy are the OIG’s recommendations on the implementation of systems to measure resident outcomes."

He also points to the plan’s emphasis on monitoring and screening employees, including temporary employees.

In addition, Sollins says the OIG is very concerned about the accuracy of billing and coding, especially as consolidated billing for those facilities draws near. "Relationships with outside vendors will need to be scrutinized closely," he warns.

Among the recommendations included in the guidance are these items:

- Make sure there is a comprehensive, accurate assessment of each resident’s functional capacity and a comprehensive care plan that includes measurable objectives to meet residents’ medical, mental and psychosocial needs.

- Refrain from discriminatory admissions or improper denial of care, verbal, mental or physical abuse, corporal punishment, and involuntary seclusion, as well as inappropriate use of physical or chemical restraints.

- Investigate the background of employees by checking with all applicable licensing and certification authorities to verify that requisite licenses and certifications are in order.

- Refrain from routinely waiving coinsurance or deductible amounts without a good-faith determination that the resident is in financial need.

- Maintain all records and documentation, including billing and claims information, that are required for participation in federal, state and private health care programs, including the resident assessment instrument, the comprehensive plan of care, and all corrective actions taken in response to surveys.

The complete nursing facility guidance is available at