Medicare Compliance & Reimbursement

Deficiency trends the top priority of OIG plan.

A survey strike against you will be an increasingly costly blow. That's the message federal regulators sent to nursing home providers in the latest annual Work Plan from the HHS Office of Inspector General.
 
In spite of reports of gains in nursing home quality in recent years, survey deficiencies are up since 1998, explains Nancy Augustine of LTCQ Inc. in Lexington, MA. And the OIG is well aware of the increase. The Work Plan specifically cites this rise in deficiencies.

Why are there more deficiencies if there is some evidence of quality gains? The dichotomy could suggest the industry is splitting into two groups: the good and the ugly. If you're not garnering better-than-average surveys, you should be increasingly worried. Soon, you are likely to face stiffer competition from top-performing facilities--and the feds are pulling out bigger enforcement guns. Watch For News On These 4 Fronts Consider these four points of focus from the OIG Work Plan, which was released Nov. 16.

• Nursing home deficiency trends. Concerns about care-related deficiencies top the list--in particular facilities that show up on the radar screen as repeat offenders. The OIG says that it will start a new study in this area and report back within the fiscal year.
 
• Enforcement action against noncompliant nursing homes. Are state and federal enforcement actions weeding out or waking up poor performers? The OIG says that it will continue to look at the effectiveness of actions such as civil monetary penalties. In large part, the agency wants to know if states are collecting the fines they levy, observes attorney Joanne Lax of Dykema Gossett PLLC in Bloomfield Hills, MI.

• State compliance with complaint investigation guidelines. The OIG wants to know if states are following up as efficiently as the feds mandate on serious resident-abuse allegations. That's within two days of immediate-jeopardy level allegations and within 10 days for allegations of actual harm.

• Nursing home residents' Minimum Data Set assessments and care planning. The OIG wants to know how many nursing home deficiencies relate back to poor assessment and care planning.