Just last month the Office of the Inspector General (OIG) put out an Industry Segment-Specific Compliance Program Guidance for Skilled Nursing Facilities and Nursing Facilities (Nursing Facility ICPG). Since 1998, the OIG has been issuing voluntary Compliance Program Guidance documents (CPGs) directed at various segments of the health care industry. At the center of this CPG modernization effort is the OIG’s General Compliance Program Guidance (GCPG), a reference guide for the health care compliance community and other health care stakeholders. The GCPG provides information about relevant Federal laws, compliance program infrastructure, OIG resources, and other useful information to understanding health care compliance. The OIG’s industry segment-specific CPGs (ICPGs) complement the GCPG with information of specific interest to various segments of the health care industry.
The Nursing Facility ICPG describes:
- Risk areas for nursing facilities
- Recommendations and practical considerations for mitigating those risk
- Other important information OIG believes nursing facilities should consider when implementing, evaluating, and updating their compliance and quality program
The User’s Guide provides a summary of some industry specific risks that all SNF owners/operators should be aware of. Compliance risks specific to the SNF are broken down into those related to Quality of Care and Quality of Life, Medicare and Medicaid Billing Requirements, Federal Anti-Kickback Statute and Other Risk Areas. The Guide is set up in the Table of Contents to efficiently direct to specific questions. Under the Quality section, focus areas include staffing, Care Plans and Resident Activities, challenges due to changes in the resident profile (acuity, behavioral health, etc.), medication management, and resident safety. These are areas of high survey deficiency.
The section on Medicare and Medicaid Billing Requirements defines critical areas to be aware of and monitor. The Guide recommends three key areas to promote compliance with SNF PPS Billing Requirements. These include:
- Developing internal policies and procedures
- Providing adequate training and education to staff
- Performing reviews and audits to confirm accurate coding and billing
As a consulting firm, LWCI most often gets involved to support a long-term care entity in the areas of Risk Assessment, Internal Review, and Monitoring Processes. Each nursing facility should develop and implement a centralized annual risk assessment, internal review, and monitoring process to identify and address risks associated with the nursing facility’s participation in Federal health care programs, including risk areas discussed in this Nursing Facility ICPG. There are no set requirements on how these tasks are to be performed; they just must be completed in such a way that the outcomes identify risk or reinforce that the facility is on the right compliance track.
LW Consulting, Inc, through efforts related to being an Independent Review Organization (IRO) supporting those under Corporate Integrity Agreements (CIA), is well qualified to assist you with a Risk Assessment or external reviews to support the monitoring process. Reach out to Kay Hashagen, [email protected] or (410) 777-5999 to discuss.
