Articles and Blogs

Requirements of Participation

Skilled Nursing Facilities: Compliance Lessons from Kirkland, Washington

[03/31/20]

Posted on March 31, 2020 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

On March 23, 2020, Centers for Medicare & Medicaid Services (“CMS”) announced the preliminary results of a recent survey of a nursing home in Kirkland, Washington, the epicenter of the COVID-19 outbreak in Washington. According to a Centers for Disease Control and Prevention (“CDC”) report, 81 residents, 34 staff and 14 visitors also became... READ MORE

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Do SNFs, HHAs and Hospice Providers Need Individual Section 1135 Waivers for COVID-19 Activities?

[03/20/20]

Posted on March 20, 2020 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

On March 13, 2020, Secretary Azar of the Department of Health and Human Services (the “HHS”) issued a letter titled “Waiver or Modification of Requirements Under Section 1135 of the Social Security Act” (the “Azar Letter”) that grants the Centers for Medicare & Medicaid Services (the “CMS”) the authority to issue waivers specific to... READ MORE

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CMS Memo Offers Additional Revised COVID-19 Guidance for Skilled Nursing Facilities

[03/16/20]

Posted on March 16, 2020 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

On March 13, 2020, the Quality, Safety & Oversight Group at the Centers for Medicare & Medicaid Services (“CMS”) issued a second revision of a memorandum entitled “Guidance for Infection Control and Prevention of Coronavirus Disease 2019 (“COVID-19”) in nursing homes (REVISED)” (“QSO Memo”) that announced recommendations for skilled nursing facilities (“SNFs”) regarding restricting visitors, transfers... READ MORE

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CMS Suspends Most Non-Emergency Inspections Across the United States with Goal to Focus on Infectious Diseases and Abuse

[03/06/20]

Posted on March 6, 2020 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

On March 4, 2020, the Quality, Safety & Oversight Group at the Centers for Medicare & Medicaid Services (“CMS”) issued a memorandum entitled “Suspension of Survey Activities” (“QSO Memo”) to announce that it is suspending non-emergency inspections across the United States so that inspectors may focus on infectious diseases and abuse. CMS states this... READ MORE

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Emergency! OIG SNF Audits Reveal Failure to Comply with Life Safety and Emergency Preparedness Regulations

[02/13/20]

Posted on February 13, 2020 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

Most skilled nursing facilities are not correctly complying with life safety requirements or emergency preparedness requirements, according to three recent reports by the Office of the Inspector General (“OIG”) of the U.S. Department of Health and Human Services. OIG recently issued three reports on its audits of life safety requirements or emergency preparedness requirements:... READ MORE

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Countdown to Phase 3 – Skilled Nursing Infection Preventionist

[10/02/19]

Posted on October 2, 2019 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

Beginning on November 28, 2019, surveyors will use the requirements detailed in 42 C.F.R. Section 483.80 of the Code of Federal Regulations Requirements for States and Long-Term Care Facilities (“Final Regulations”) to determine whether a skilled nursing facility (“Facility”) has an infection preventionist on staff who is a primary professional trained in nursing, medical... READ MORE

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CMS Proposes One-Year Delay for Certain Phase 3 Skilled Nursing Requirements – Changes Made to Compliance and Ethics Programs and Quality Assurance and Performance Improvement Programs

[07/17/19]

Posted on July 17, 2019 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

On July 16, 2019, the Centers for Medicare & Medicaid Services (“CMS”) released a pre-publication copy of the revisions (“Proposed Rule”) to Part 483 to Title 42 of the Code of Federal Regulations the Requirements for States and Long-Term Care Facilities (“RoPs”). CMS stated that it identified a number of existing skilled nursing facility... READ MORE

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CMS Updates Requirements to Reduce Legionella Risk in Health Care Facility Water Systems and Identifies Surveyor Expectations – Review of Policies and Procedures Required

[07/12/18]

Posted on July 12, 2018 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

On July 6, 2018, the Survey and Certification Group at the Centers for Medicare & Medicaid Services (“CMS”) revised its memorandum, “Requirement to Reduce Legionella Risk in Healthcare Facility Water Systems to Prevent Cases and Outbreaks of Legionnaires’ Disease (LD)” (“S&C Memo”), that requires that facilities develop and follow policies and procedures that inhibit... READ MORE

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CMS Issues 18-Month Moratorium and Delays Enforcement of Some Phase 2 Requirements for Long-Term Care Facilities

[11/27/17]

Posted on November 27, 2017 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

This is another article in a series discussing the complete overhaul of Part 483 to Title 42 of the Code of Federal Regulations, the Requirements for States and Long-Term Care Facilities (“Final Regulations”) by the Centers for Medicare & Medicaid Services (“CMS”). BACKGROUND On September 28, 2016, CMS released a complete overhaul of Part... READ MORE

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Countdown to Phase II Compliance: The Facility Assessment for Long-Term Care Facilities – Review of Facility Resident Population and Resources Required

[08/22/17]

Posted on August 22, 2017 in Long-Term Care, Home Health & Hospice

Published by: Hall Render

This is another article in a series discussing the complete overhaul of Part 483 to Title 42 of the Code of Federal Regulations, the Requirements for States and Long-Term Care Facilities (“Final Regulations”) by the Centers for Medicare & Medicaid Services (“CMS”). Hall Render published an overview of Final Regulations components as well as Parts 1,... READ MORE

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