For Your Health:
Keeping the Pulse of the Law
Don’t expose yourself to unnecessary risks. Documentation containing inadvertent errors can often times be used as the basis for civil lawsuits and criminal prosecutions before those accused have the opportunity to explain or correct those errors. SNF scrutiny in a politically charged environment warrants operators to place additional emphasis on documentation compliance to avoid issues.
We highlight a recent advisory opinion, OIG Advisory Opinion No. 21-18, regarding a long term care provider’s proposed arrangement with a therapy services vendor. The facts presented in the Opinion are straightforward and include elements not unlike many typical joint venture (JV) and management service organization (MSO) arrangements in the health care space.
The Centers for Medicare & Medicaid Services (CMS) has announced that it will use payroll-based journal (PBJ) data to identify nursing homes that have several days in a quarter without a registered nurse (RN) on site, or have a significant decline in staff on the weekends. The States will be required to inspect such facilities and cite any non-compliance resulting from such surveys.
