- THCA

Volume XXX, Number 12
December 2015

2016 OIG Work Plan: Long Term Care Facilities Areas of Focus

The United States Health and Human Services Office of the Inspector General (“OIG”) published its Fiscal Year 2016 Work Plan (“2016 Plan”) on November 2, 2015. The work plan is published annually by the OIG and identifies new and ongoing investigative, enforcement and compliance priorities for the OIG in the upcoming year. A complete copy of the 2016 Plan may be accessed here.

OIG announced the following initiatives with regard to long term care facilities:

Skilled Nursing Facility Prospective Payment System Requirements:
New for 2016 is an initiative focused on skilled nursing facility (“SNF”) prospective payment system requirements. OIG will review for compliance with these requirements, with an emphasis on whether SNFs are completing and maintaining appropriate documentation to support claims paid by Medicare. OIG has previously concluded that SNFs increasingly billed for the highest level of therapy even though key beneficiary characteristics remained largely the same. OIG will also look for compliance with the documentation requirements specified in 42 C.F.R. § 483.20 in support of the reasonableness and necessity of the care provided by the SNF (e.g., a physician order for care at the time of admission, a comprehensive assessment, and a comprehensive plan of care).
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State Agency Verification of Deficiency Corrections:
Another new 2016 initiative will focus on whether State survey agencies verified correction plans for deficiencies identified during nursing home recertification surveys. A prior OIG review found that one State survey agency did not always verify that nursing homes corrected deficiencies identified during surveys in accordance with Federal requirements. Federal regulations require nursing homes to submit correction plans to the State survey agency or Centers for Medicare and Medicaid Services (“CMS”) for deficiencies identified during surveys. (42 CFR § 488.402(d).) CMS requires State survey agencies to verify the correction of identified deficiencies through onsite reviews or by obtaining other evidence of correction.
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National Background Check Program for Long Term Care Employees:
Continued from 2015 is an initiative focused on the National Background Check Program for long-term-care employees, a program implemented pursuant to section 6201 of the Patient Protection and Affordable Care Act (“ACA”). This program requires national and state background checks for prospective employees of nursing homes and other long-term-care providers, and OIG will report the status and results to date from the program’s first four years.
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Medicaid Beneficiary Transfers from Group Homes and Nursing Facilities to Hospital Emergency Rooms:
Another OIG initiative from 2015 which will continue in 2016 will review the rate of and reasons for transfer from group homes or nursing facilities to hospital emergency departments. High occurrences of emergency transfers could indicate poor quality. Prior OIG work examined transfers to hospital emergency departments, raising concerns about the quality of care provided in some nursing facilities.

President’s Report

President’s Report

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Legislative Update

House Speaker Announces Interim Charges

THCA Honors Estes for Leadership on Long Term Care Issues

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Commitment to Care

One a Month Campaign

Register Today – THCA Members Only Webinar Your 5-STAR Rating Really IS in Your Control – December 8

DADS is Accepting Applications for Civil Money Penalty Project Funding

Updated Texas Minimum Data Set Resources

Taking the Pulse of Person-Centered Care

DADS Asking for Nurses Feedback on CE Needs and Preferences

DADS Joint Training Opportunities in December and January

If you have any questions about the THCA C to C Initiative or would like to share your facilities successes please contact Gloria Bean-Williams at gbwilliams@txhca.org or call (512) 458-1257.

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