The Office of the Inspector General (OIG) released its March 2014 Compendium of Priority Recommendations, outlining some of the key initiatives that it has provided recommendations for that have not yet been satisfactorily addressed. There are many recommendations that will impact skilled nursing facilities, particularly around the survey process. Here’s a recap of the OIG’s recommendations for promoting compliance and reducing fraudulent billing.
Addressing resident harm, questionable resident hospitalizations and inappropriate drug use
- Most recently, a February 2014 OIG report found that 59% of adverse and temporary harm events during SNF stays are preventable. The OIG recommended that CMS instruct surveyors to review facility practices on identifying and reducing adverse events.
- As part of its 2013 Work Plan, the OIG released a report that found that one-quarter of nursing home residents were transferred to hospitals in 2011, which created $14.3 billion in Medicare reimbursements. The agency recommended that a Quality Measure should be created that tracks the rate of resident hospitalizations and that CMS should instruct surveyors to review these rates during certification surveys.
- The OIG initially announced that a new area of focus in its 2013 Work Plan would be a review of the use of atypical antipsychotic drugs in nursing home. This report stemmed from the agency’s July 2012 report that found that 99% of records reviewed failed to meet one of more of the Federal requirements for resident assessments and/or care plans. However, the research required for the review of atypical antipsychotic drugs was ultimately put off due to budget cuts. In a separate report issued in May 2011, the OIG had recommended that CMS develop alternative methods for assessing compliance with Federal standards for reducing unnecessary drugs during survey. CMS has responded to this in several ways, including issuing updated surveyor guidance on assessing a nursing facility’s compliance with F-329 Drug Regimen Free from Unnecessary Drugs and F-309 Provide Care/Services for Highest Well Being.
Improving emergency preparedness and response in nursing homes
- In July 2012, the OIG issued a report that showed there has been a decrease in compliance rates for nursing homes meeting Federal requirements for emergency planning and emergency training. The OIG recommended that CMS strengthen regulations in this area to include specific elements of emergency planning and training and update the SOM to provide more guidance to surveyors in this area. CMS has already taken some of these recommendations into account, first by issuing a proposed rule on emergency preparedness standards for LTC facilities and also by releasing an updated nursing facility emergency preparedness checklist this past February.
Improving care planning efforts and discharge planning in nursing homes
- When the OIG reported in 2013 that $5.1 billion was paid in Medicare reimbursements for inferior quality of care, inadequate care plans and poor discharge planning, this should have been an eye opener for many providers to step up their game in these areas. The OIG recommended that CMS strengthen care planning and discharge regulations and encourage surveyors to identify and hold accountable SNFs that did not meet these requirements. The agency also recommended that payments should be linked to quality of care requirements.
Should your facility require assistance in any of these areas, CMS Compliance Group’s knowledgeable consultants can provide assistance. Contact us today.
