GreisGuide to LTACHs » snf

CMS Rule Expands Long-Term Care Facility Administrators’ Responsibility to Report Facility Closures

Jason Greis — Thu, 03 Mar 2011 04:11:37 +0000

On February 18, 2011, the Centers for Medicare and Medicaid Services (CMS) issued an interim final rule (Interim Rule) implementing Section 6113 of the Patient Protection and Affordable Care Act (PPACA). The Interim Rule, which becomes effective March 23, 2011, requires administrators of long-term care facilities (LTCF), including skilled nursing facilities (SNF) eligible for reimbursement under Medicare and nursing facilities (NF) eligible for reimbursement under Medicaid, to submit prior written notification of an impending LTCF closure to the Secretary of the U.S. Department of Health and Human Services (Secretary), the state’s long-term care ombudsman and residents of the facility and their legal representatives or other responsible parties. LTCF administrators that do not comply with the new notice requirements may face sanctions, including civil monetary penalties of up to $100,000 and exclusion from participation in Federal health care programs. In addition, LTCFs must have related policies in place to avoid being cited for survey deficiencies. Read More...

2011 Medicare Payment Update for Post-Acute Care Providers

Jason Greis — Wed, 04 Aug 2010 03:44:05 +0000

The Centers for Medicare & Medicaid Services (“CMS”) has recently released various notices and final rules updating 2011 Medicare payment rates for post-acute care providers, including long-term acute care hospitals (“LTACHs”), inpatient rehabilitation facilities (“IRFs”), skilled nursing facilities (“SNFs”), home health agencies (“HHAs”) and hospices. These Medicare rate updates generally implement negative payment adjustments mandated by the Patient Protection and Affordable Care Act (Pub. L. No. 111-148), as amended by the Health Care and Education Reconciliation Act of 2010 (Pub. L. No. 111-152) (together, “PPACA”). Yet in spite of these adjustments, SNFs, hospices, IRFs and LTACH have fared relatively well with collective Medicare payment increases totaling $919 million, with HHAs offsetting these reimbursement gains by suffering a proposed $900 million Medicare reimbursement cut for calendar year 2011. Read More...

McGuireWoods 2010 North Carolina Healthcare Provider Conference and Post-Acute & Senior Care Conference

Jason Greis — Wed, 23 Jun 2010 02:27:07 +0000

[ October 7, 2010; 12:00 pm to 5:00 pm. October 8, 2010; ] Please join us in Charlotte, North Carolina on Thursday, October 7 and Friday, October 8, 2010 for a two-day conference addressing the impact of Federal health care reform on post-acute and senior care care providers across the continuum of care. Additional registration information and the final agenda will be posted here by mid-July.

Post-Acute Care Investments: Key Business, Deal Structure and Diligence Issues

Jason Greis — Wed, 23 Jun 2010 02:15:16 +0000

[ June 24, 2010; 12:30 pm to 1:30 pm. ] Post-Acute Care Investments: Key Business, Deal Structure & Diligence Thursday, June 24, 2010 12:30 - 1:30 p.m. (ET) | 11:30 a.m. - 12:30 p.m. (CT) | 9:30 a.m. - 10:30 p.m. (PT) Complimentary Webinar Please join us for the second in a series of informative webinars where we will delve into investing in different healthcare segments. Our second program deals [...]

Virtues and Vices of Medicare Episode of Care Payment Bundling: A Look at PPACA’s Pilot Program

Jason Greis — Fri, 30 Apr 2010 18:55:11 +0000

The attached presentation addressing the potential benefits and drawbacks of CMS’s Pilot Program under PPACA to develop an episode of care bundled payment model for acute care, post-acute care, physician and outpatient services was presented at the Chicago Bar Association on Friday, April 30, 2010. Please feel free to contact me if you have any questions. Read More...

Illinois Not-for-Profit Property Tax Exemptions, Charity Care and the Provena Decision

Jason Greis — Wed, 24 Mar 2010 02:49:39 +0000

Late last week the Illinois Supreme Court (the Court) issued its long-anticipated decision in the case of Provena Covenant Medical Center v. Illinois Department of Revenue (Provena). The Court’s opinion, delivered by Justice Karmeier, upheld the Illinois Department of Revenue (Revenue) Director Brian Hamer’s ruling that Provena Covenant Medical Center, located in Urbana, Ill. (PCMC), did not provide enough charity care services to justify the continuation of its charitable purpose property tax exemption. The Court’s opinion noted that PCMC’s parent company, Provena Hospitals, was the true property owner of PCMC, and that Provena Hospitals itself was not a charitable institution nor did it primarily serve charitable purposes. Furthermore, the Court held that PCMC provided only minimal levels of charity care thus the property was not being primarily used for charitable purposes. The Court’s decision will be problematic for not-for-profit hospitals, including LTACHs, because it leaves a key question unanswered—just how much charity must a hospital provide to justify an exemption? The decision is expected to encourage local taxing bodies to pursue efforts to remove tax exemptions of not-for-profit hospitals and other providers. Read More...

MedPAC Releases 2010 Final Report Recommending Payment Updates for LTACHs and other FFS Providers

Jason Greis — Tue, 02 Mar 2010 04:00:05 +0000

On March 1, 2010, the Medicare Payment Advisory Commission (“MedPAC” or the “Commission”) released its 2010 Report to the Congress: Medicare Payment Policy (the “Final Report”). The purpose of the Final Report is to recommend annual Medicare payment updates for the following nine Medicare fee-for-service (“FFS”) payment systems: hospitals, physicians, ambulatory surgery centers, outpatient dialysis services, hospices, skilled nursing facilities, home health services, inpatient rehabilitation facility services and long-term acute care hospital services. Read More...

GreisGuide to LTACHs Newsletter (August/September 2009)

Jason Greis — Sun, 20 Sep 2009 18:53:35 +0000

This issue of the GreisGuide to LTACHs Newsletter contains articles and information on: Read More...

Senate Finance Committee Healthcare Bill: Highlighting Provisions of the Chairman’s Mark Applicable to Post-Acute Care Providers

Jason Greis — Fri, 18 Sep 2009 02:39:39 +0000

On Wednesday, September 17, 2009, Senator Max Baucus released the long-awaited Chairman's Mark of the Senate Finance Committee’s proposed health care overhaul bill. The Bill largely reflects the major goals outlined by President Obama in his speech before Congress last week. The Bill contains a number of provisions that, if enacted, would significantly impact post-acute care service delivery models and Medicare and Medicaid reimbursement to LTACHs, IRFs, SNFs, HHAs and hospices. This article highlights some of the proposals outlined in the Bill that are most relevant to the post-acute care provider community.

LTACHs and other Post-Acute Providers are Not Eligible for Funds to Implement EHR Technology under the HITECH Act

Jason Greis — Fri, 07 Aug 2009 16:53:08 +0000

Many LTACHs and other post-acute care providers have inquired whether they are eligible to apply for and receive incentive payments to adopt certified electronic health record (“EHR”) technology under the Health Information Technology for Economic and Clinical Health Act (the “HITECH Act” or the “Act”). To put it simply, the answer appears to be “no.” Read More...