The HCPro long-term care team recently posed a few questions to the readers of our periodicals for nursing home providers to better understand how professionals in the field are gearing for the impending introduction of the payroll-based staffing journal (PBJ)—an electronic system through which, starting in July 2016, SNFs will be required to submit staffing data pulled directly from their payrolls. In particular, we wanted to gauge provider interest in the opportunity CMS has begun offering this month: submitting data through the PBJ before the practice becomes mandatory.
On July 13, 2015, the Centers for Medicare & Medicaid Services (CMS) announced a proposal to improve the quality of care and safety affecting long-term care residents. Regulations regarding reduction of unnecessary hospital readmissions and infections, increased quality of resident care, and strengthened safety measures top the major revisions in CMS’ proposed rule CMS-3260-P, which is expected to be released in the July 16, 2015, Federal Register.
Although the SNF prospective payment system (PPS) was implemented to remedy widespread billing problems in long-term care, the reimbursement methodology—and its consolidated billing requirements for facilities and their business partners—has come with its own host of challenges. Since the inception of PPS, CMS has identified several major problematic SNF practices related to consolidated billing.
The second most important function an executive and/or a governance board conducts (second only to planning) is risk management. This key leadership function is evolving rapidly primarily due to the evolutionary movement around compliance (ACA, CMS, etc.) and the payer focal shift from episodic, procedural care to outcome or evidence-based care, pay-for-performance, etc. Similarly, as government policy shifts, so does commercial market dynamics with like movements toward pay-for-performance and disease management. While the core concept of “enterprise” protection remains the same, the scope today is different, the breadth wider and the responsibilities and tasks more structured than say, 10 plus years ago.
After remaining stagnant for 25 years, the CMS Conditions of Participation (CoP) for long-term care facilities are poised to receive a much-needed makeover. First published in 1989, the current LTC CoPs have remained largely unchanged over the years, barring a few minor tweaks in 1991. In July, however, CMS issued proposed updates to the outdated provisions, bringing the regulatory language and requirements into the 21st century.