Corporate Compliance Program Updates National Association of
State Veterans Homes March 2015 Presented by: Eileen Denzel RHIA,
CCS Director of Compliance/Privacy Officer Long Island State
Veterans Home Stony Brook, New York [email protected] (631)
444-8646
Slide 2
Celebrate Corporate Compliance & Ethics Week November 1-7,
2015 Many organizations use the week as an opportunity to raise
awareness about compliance and ethics and engage employees about
these difficult yet vitally important topics. Others use the week
to rollout a new compliance training program or hold its annual
compliance training activities.
Slide 3
Celebrate Corporate Compliance & Ethics Week the first full
week of November in 2015. To better align the timing of Corporate
Compliance & Ethics Week with the implementation of the Federal
Sentencing Guidelines (Nov. 1, 2004), it will now be held during
the first full week in November every year
Slide 4
Identified Compliance Program Best Practices
Slide 5
Element (1) Written policies and procedures: 1.Publication of
code of conduct and/or compliance plan document on the providers
intranet and/or public Web site. 1.Language in the compliance plan
outlines the benefits of a corporate compliance program as a way to
obtain buy in from the providers constituency.
Slide 6
Element (2) Designate an employee vested with responsibility:
1.The compliance officer reports directly to the governing board,
with dotted line responsibility to a member of senior management.
2.The chief executive officer receives regular reports from the
compliance officer if the compliance officer does not report
directly to the CEO.
Slide 7
Element (3) Training and Education: 1.Use of an electronic
training and education system that tracks mandatory compliance
education of employees via an electronic system which: a. is
customized to the organization; b. sends an individualized e mail
to employees to announce upcoming required and elective training;
and c. tracks each employees required compliance training and
educational needs. 2.Results of online compliance education quiz
scores are analyzed and tracked to identify areas of weakness for
both the education program and for those being trained.
Slide 8
Element (3) Training and Education: 3.Additional training and
education is provided based on this analysis. Results of the online
post test quizzes are utilized to identify risk areas and assess
the need for internal monitoring and auditing. 4.The compliance
training and educational materials are tailored to the needs of
differing organizational levels as well as the educational
backgrounds of all employees. 5.The compliance manual/code of
conduct is distributed annually and upon hire.
Slide 9
Element (4) Communication lines to the responsible compliance
position: 1.The compliance program operates in an environment of
transparency throughout the organization and includes communication
lines among the president/director, senior management, and
employees. 2.Human resource departments exit interviews of
employees include specific compliance related questions that are
fed back to the compliance function.
Slide 10
Element (5) Disciplinary policies to encourage good faith
participation: 1.Employee performance evaluations incorporate
compliance as one indicator of performance, as well as an employees
adherence to applicable laws, regulations, and policies. Element
(6) A system for routine identification of compliance risk areas:
1.The Compliance Program uses a comprehensive self assessment tool
to plan and develop an annual compliance work plan.
Slide 11
Element (6) A system for routine identification of compliance
risk areas: 2.A compliance dashboard centralizes information to
track and provide reports on compliance activities. 3. Internal
monitoring and auditing systems are used throughout the agency as
evidenced by: a. Teams of cross trained peer reviewers, who conduct
quarterly case record reviews in each program area to ensure that
documentation complies with established requirements and to ensure
quality of service provided. This review is conducted as part of a
quality improvement program. b. A pre claim review process is used
prior to submission of claims to address billing and coding errors
and weaknesses.
Slide 12
Element (6) A system for routine identification of compliance
risk areas: 4.Identified risk areas are tracked month to month,
analyzed, and trended to monitor the identified risk area activity.
The data is shared with committee members and the governing board
with the goal of improving the number of identified risk areas,
processes, and outcomes. 5.Individualized sampling of medical
records is conducted to assess the accuracy of ordered services and
whether the services were actually rendered.
Slide 13
Element (7) A system for responding to compliance issues:
1.Review OMIGs, OIGs and CMS Web sites for regulatory work plans
and alerts associated with specific areas of focus, assess
organizational risk in those areas and develop appropriate action
plans to address the risk or weakness. Element (8) A policy of non
intimidation and non retaliation: 1.Exit interviews with employees
include an interview with the Compliance Officer who inquires about
cases of intimidation or retaliation related to the employee who is
departing service and; related to what the departing employee may
have observed while employed.
Slide 14
Compliance Meeting Agenda Items Sanction Screening Gifts
Helpline Calls Departmental Auditing Monitoring External Audits
OIG/ OMIG Work Plan Items Compliance News HIPAA Consultant Update
Compliance Activities in the Industry
Slide 15
Program Integrity and Quality of CareAn Overview for Nursing
Home Providers
Slide 16
Content Summary This booklet is written for nursing home
providers and contains information on the definitions for fraud,
waste, and abuse, and common types of fraud in the nursing home
environment. This booklet also discusses improper payments and
government anti-fraud efforts. After addressing common program
integrity issues, the booklet covers quality of care in the nursing
home, such as quality of life, resident rights, and resident
freedom from fraud and abuse. The booklet concludes with
information on how to report concerns and problems in the nursing
home. http://www.cms.gov/Medicare-Medicaid-
Coordination/Fraud-Prevention/Medicaid-Integrity-
Education/Downloads/nursinghome-provider-booklet.pdf
http://www.cms.gov/Medicare-Medicaid-
Coordination/Fraud-Prevention/Medicaid-Integrity-
Education/Downloads/nursinghome-provider-booklet.pdf
Slide 17
Slide 18
Slide 19
Slide 20
https://oig.hhs.gov/newsroom/video/2011/heat_modules.asp HEAT
Provider Compliance Training Videos Videos and Audio Podcasts This
page contains videos and audio podcasts that are part of the
award-winning Health Care Fraud Prevention and Enforcement Action
Team (HEAT) Provider Compliance Training initiative. These are
educational presentations designed to help prevent fraud, waste,
and abuse.
Slide 21
A particular OIG concern is how CMS contractors address fraud
vulnerabilities directly related to Medicare health claims. OIG
notes that audit logs can be used to analyze historical patterns
that can identify data inconsistencies. To provide the most benefit
in fraud protection, audit logs should always be operational, be
stored as long as clinical records, and never be altered. OIG goes
further in noting that few integrity contractors analyze audit logs
as part of medical review. OIG Wants Medicare to Probe EHR Audit
Logs for Fraud
Slide 22
OIG recommends that CMS direct its contractors to review
providers audit logs. As OIG pointed out, experts in health
information technology caution that HER technology can make it
easier to commit fraud. For instance, the copy paste feature allows
users to replicate information in one source and transfer the
information to another source. Overuse or inappropriate use of
copy-paste could produce inaccurate information and facilitate
fraudulent claims. In addition, some EHRs provide templates that
auto-populate fields by a single click, resulting in extensive
documentation. As OIG notes, the use of audit logs may reveal such
data inconsistencies andprovide the most benefit in fraud
detection. EHR Audit Logs
Slide 23
What an Audit Trail Reveals: An audit log is a record of how
information is entered, revised, or deleted in an EHR. identify the
patient; identify the EHR user; identify the type of action, such
as printing or copying data, submitting data queries, or entering,
revising, or deleting data; and identify the patient data being
accessed. EHR Audit Logs
Slide 24
LISVH COMPLIANCE ASSURANCE HOTLINE If you have a compliance
question or concern Call the CONFIDENTIAL Compliance Hotline at
631-689-2179 Or Contact Eileen Denzel, Compliance Officer, 444-8646
[email protected]
Slide 25
CDC Website for LTC Website launched January 23, 2014 Focuses
on Infection Control prevention in Long term care facilities CDC
Infection Prevention website for long term care
http://www.cdc.gov/longtermcare/ Email list for PEPPER
www.pepperresources.com Medicare Update Info
http://www.cms.gov/mlnmattersarticles
Slide 26
OCTOBER 2015 ICD-10 COMPLIANCE DATE
http://www.cms.gov/Medicare/Coding/ICD10/ProviderResour ces.html
CMS Releases Two New ICD-10 Videos The Centers for Medicare &
Medicaid Services (CMS) has released two animated shorts that
explain key ICD-10 concepts. Less than 4 minutes each, the videos
are available at: cms.gov/ICD-10
Slide 27
Introduction to ICD-10 CodingIntroduction to ICD-10 Coding
gives an overview of ICD- 10s features and explains the benefits of
the new code set to patients and to the health care community.
ICD-10 Coding and DiabetesICD-10 Coding and Diabetes uses diabetes
as an example to show how the code set captures important clinical
details. Keep Up to Date on ICD-10 Visit the CMS ICD-10 website for
the latest news and resources to help you prepare.ICD-10
website
Slide 28
CMS Issues Official ICD-10-CM Guidelines
http://www.cdc.gov/nchs/data/icd/icd10cm_gui delines_2015.pdf
http://www.cdc.gov/nchs/data/icd/icd10cm_gui delines_2015.pdf These
guidelines should be used as a companion document to the official
version of the ICD-10-CM as published on the NCHS website.
Slide 29
Disposal of PHI All PHI must be disposed of properly in a GRAY
confidential bin. Examples of PHI include resident name, resident
photo, diagnosis, room #, account and medical record #, address,
phone number, birth date, social security #. Examples include phone
messages, pharmacy and medical record labels, faxes, statements and
reports. If your bin requires service, please call Environmental
Services at x790.
Slide 30
HIPAA Updates New rule protects patient privacy, secures health
information Enhanced standards improve privacy protections and
security safeguards for consumer health data. The U.S. Department
of Health and Human Services (HHS) moved forward to strengthen the
privacy and security protections for health information established
under the Health Insurance Portability and Accountability Act of
1996 (HIPAA). The U.S. Department of Health and Human Services
(HHS) moved forward to strengthen the privacy and security
protections for health information established under the Health
Insurance Portability and Accountability Act of 1996 (HIPAA).
Notice of Privacy Practices (NPP)-update Business Associate
Agreements (BAA)-update
Slide 31
Notice of Privacy Practices Updates: A statement that the
following uses and disclosures will be made only with authorization
from the individual: uses and disclosures for marketing purposes;
uses and disclosures for marketing purposes; uses and disclosures
that constitute the sale of PHI; uses and disclosures that
constitute the sale of PHI; most uses and disclosures of
psychotherapy notes (if the covered entity maintains psychotherapy
notes); and most uses and disclosures of psychotherapy notes (if
the covered entity maintains psychotherapy notes); and other uses
and disclosures not described in the notice other uses and
disclosures not described in the notice A statement regarding an
individuals right to notice in the event of a breach.
Slide 32
Notice of Privacy Practices Updates: Notice of the right to opt
out of fundraising communications (if the covered entity conducts
fundraising). Health care providers must include in their notice of
privacy practices a statement about an individuals right to
restrict disclosures of protected health information to health
plans if an individual has paid for services out of pocket in full.
All covered entities must revise their notice of privacy practices
by September 23, 2013. The revisions constitute a material
modification to the notice, and therefore the revised notice must
be made available to individuals as follows:
Slide 33
Health care providers: The revised notice must be available to
existing patients upon request, and must be posted both to the
providers website (if they have a website) and in a prominent
location on the premises. New patients must be provided with a copy
of the revised notice. Notice of Privacy Practices Updates:
Slide 34
Business Associates Updates: Business Associates (BA) are now
defined to include a broader array of contractors that store and
touch PHI including, for example, document storage companies and
other contractors that maintain PHI, even if they do not actually
view the information in their possession.
Slide 35
Business Associates Updates: For BA agreements you already had
in place as of Jan. 25, 2013, you have until Sept. 22, 2014, to
bring them into compliance with the 2013 HIPAA omnibus rules.
Remember, if you amend an existing BA agreement after Jan. 25,
2013, the amended version must be in compliance with the 2013 HIPAA
omnibus rules. The rules also extended liability under the HIPAA
privacy and security rules to BAs as well as to their
subcontractors.
Slide 36
QAPI QAPI is a data-driven, proactive approach to improving the
quality of life, care, and services in nursing homes. The
activities of QAPI involve members at all levels of the
organization to: identify opportunities for improvement; address
gaps in systems or processes; develop and implement an improvement
or corrective plan; and continuously monitor effectiveness of
interventions.
Slide 37
QAPI Update A Process Tool Framework has been created to
crosswalk each CMS Process Tool to the QAPI Five Elements. This
framework includes a description of the purpose or goal for each
tool that is hyperlinked within the framework.
http://www.cms.gov/Medicare/Provider-Enrollment-
and-Certification/QAPI/NHQAPI.html
http://www.cms.gov/Medicare/Provider-Enrollment-
and-Certification/QAPI/qapitools.html
Slide 38
Office of Inspector General Work Plan Fiscal Year 2015
http://oig.hhs.gov/reports-and-
publications/archives/workplan/2015/FY15-Work-Plan.pdf
http://oig.hhs.gov/reports-and-
publications/archives/workplan/2015/FY15-Work-Plan.pdf Medicare
Part A billing by skilled nursing facilities: We will describe
changes in SNF billing practices from FYs 2011 to 2013. Prior OIG
work found that SNFs increasingly billed for the highest level of
therapy even though beneficiary characteristics remained largely
unchanged. OIG also found that SNFs billed one-quarter of all 2009
claims in error; this erroneous billing resulted in $1.5 billion in
inappropriate Medicare payments. CMS has made substantial changes
to how SNFs bill for services for Medicare Part A stays. (OEI;
02-13-00610; various reviews; expected issue date: FY 2015)
Slide 39
Office of Inspector General Work Plan Fiscal Year 2015
Questionable billing patterns for Part B services during nursing
home stays: We will identify questionable billing patterns
associated with nursing homes and Medicare providers for Part B
services provided to nursing home residents during stays not paid
under Part A (for example, stays during which benefits are
exhausted or the 3-day prior-inpatient-stay requirement is not
met). A series of studies will examine several broad categories of
services, such as foot care. Congress directed OIG to monitor Part
B billing for abuse during non-Part A stays to ensure that no
excessive services are provided. (OEI; 06-14- 00160; various
reviews; expected issue date: FY 2015) HHS OIG Work Plan | FY 2015
Medicare Program
Slide 40
Office of Inspector General Work Plan Fiscal Year 2015 State
agency verification of deficiency corrections: We will determine
whether State survey agencies verified correction plans for
deficiencies identified during nursing home recertification
surveys. A prior OIG review found that one State survey agency did
not always verify that nursing homes corrected deficiencies
identified during surveys in accordance with Federal requirements.
Federal regulations require nursing homes to submit correction
plans to the State survey agency or CMS for deficiencies identified
during surveys. (42 CFR 488.402(d).) CMS requires State survey
agencies to verify the correction of identified deficiencies
through onsite reviews or by obtaining other evidence of
correction. (State Operations Manual, Pub. No. 100-07, 7300.3.)
various reviews; expected issue date: FY 2015)
Slide 41
Office of Inspector General Work Plan Fiscal Year 2015 Program
for national background checks for long-term-care employees: We
will review the procedures implemented by participating States for
long-term-care facilities or providers to conduct background checks
on prospective employees and providers who would have direct access
to patients and determine the costs of conducting background
checks. We will determine the outcomes of the States' programs and
determine whether the programs led to any unintended
consequences.
Slide 42
Section 6201 of the Patient Protection and Affordable Care Act
(ACA) requires the Secretary of Health and Human Services to carry
out a nationwide program for States to conduct national and State
background checks for prospective direct patient access employees
of nursing facilities and other long-term-care providers. Office of
Inspector General Work Plan Fiscal Year 2015
Slide 43
The program is administered by CMS. To carry out the nationwide
program, CMS has issued solicitations for grant awards. All States,
the District of Columbia, and U.S. territories are eligible to be
considered for a grant award. OIG is required under the ACA to
submit a report to Congress evaluating this program. This mandated
work is ongoing and will be issued at the program's conclusion, as
required. (ACA, 6401.) (OEI; 07-10-00420; expected issue date: FY
2015; ACA) Office of Inspector General Work Plan Fiscal Year
2015
Slide 44
Hospitalizations of nursing home residents for manageable and
preventable conditions: We will determine the extent to which
Medicare beneficiaries residing in nursing homes are hospitalized
as a result of conditions thought to be manageable or preventable
in the nursing home setting. A 2013 OIG review found that 25
percent of Medicare beneficiaries were hospitalized for any reason
in FY 2011. Hospitalizations of nursing home residents are costly
to Medicare and may indicate quality-of- care problems in nursing
homes. (OEI; 06-11-00041; expected issue date: FY 2015) Office of
Inspector General Work Plan Fiscal Year 2015
Slide 45
New York State Office of the Medicaid Inspector General (OMIG)
2014-15 Work Plan
http://www.omig.ny.gov/images/stories/work_plan/2014-
15_work_plan.pdf
http://www.omig.ny.gov/images/stories/work_plan/2014-
15_work_plan.pdf The Residential Health Care Facilities (RHCF)
Business Line Team reviews nursing facilities and assisted living
programs (ALP). RHCFs are reimbursed for covered services to
eligible consumers based on determined rates. An ALP provides
long-term residential care, room, board, housekeeping, personal
care, supervision, and provides or arranges for home health
services to five or more eligible residents unrelated to the
operator..
Slide 46
New York State Office of the Medicaid Inspector General (OMIG)
2014-15 Work Plan Base Year Audits: RHCFs use the same reported
costs, with appropriate trend factors, for multiple years of
reimbursement. The Office of the Medicaid Inspector General (OMIG)
will review new base year rates approved by the Department of
Health (DOH). OMIG reviews will focus on inappropriate and
unallowable costs included in the new RHCF rates. OMIG will also
review add-ons to determine whether they were appropriately
calculated. Capital: Reported RHCF capital costs are used as a
basis for the capital component of the RHCF Medicaid rate. OMIG
will audit underlining costs included within the capital component
and if necessary, make appropriate adjustments to the rates
Slide 47
New York State Office of the Medicaid Inspector General (OMIG)
2014-15 Work Plan Medicaid Rate Part B Offset Medicaid rates for
nursing facilities include billable rates for Medicaid consumers
who may or may not be eligible for Medicare Part B service
reimbursement. The difference between the non-eligible and eligible
rates is called the Part B Offset. OMIG has developed an approach
to systematically capture the Part B reimbursement information
associated with Medicaid consumers through data gathering and
computer matches with the Centers for Medicare and Medicaid
Services. OMIG will conduct risk assessments and perform reviews of
the Part B Offset for facilities that are rated as high risk and
will also review any appeals processed by DOH.
Slide 48
New York State Office of the Medicaid Inspector General (OMIG)
2014-15 Work Plan Bed Reservations: When qualifying criteria are
met, the Medicaid program reimburses nursing facilities on a per
diem basis to hold a residents bed while that resident is
temporarily absent from the facility. OMIG will review nursing
facilities reserved bed payments to determine whether facilities
are qualified to receive these payments.
Slide 49
New York State Office of the Medicaid Inspector General (OMIG)
2014-15 Work Plan Minimum Data Set: OMIG will review Minimum Data
Set submissions from nursing facilities. During State Fiscal Year
2014-2015, OMIG will collaborate with DOH to initiate reviews of
data submissions. Notice of Rate Changes (Rollovers): Reported base
year operating costs are increased by an inflation factor (also
known as a trend factor) and used as a basis for RHCF rates for
subsequent years. OMIG will carry forward base year operating cost
audit findings and adjust rates accordingly. Rate Appeals: RHCFs
may file rate appeals with DOH to contest their Medicaid rates.
OMIG will review rate appeals that have been approved by DOH and,
where indicated, audit underlying costs associated with those
appeals to determine the appropriateness of each appeal issue.
Slide 50
Sanction Screening Under Federal law, no payment will be made
by any Federal health care program, including Medicare or Medicaid,
for any items or services furnished, ordered, or prescribed by an
excluded individual or entity. Exclusions from participation in
Federal health care programs are imposed by the Department of
Health and Human Services (DHHS) Office of Inspector General (OIG).
The OIG advises that all current and new employees, medical
personnel, contractors, and vendors should be screened against the
latest version of the OIG List of Excluded Individuals and Entities
(LEIE), which is published on its web site:
https://oig.hhs.gov/exclusions/index.asp on a monthly basis.
https://oig.hhs.gov/exclusions/index.asp
Slide 51
Sanction Screening The OIG further recommends regular screening
of the General Services Administration System of Awards Management
(SAM) List of Parties Excluded from Federal Procurement and
Non-procurement Programs). Similarly, the DHHS Centers for Medicare
& Medicaid Services (CMS), has advised that providers may not
employ, contract with or receive Medicare or Medicaid payments for
items or services furnished by individuals or entities excluded
from participation in any health care program, or debarred by the
SAM, or receive Medicare or Medicaid payments for items or services
furnished, ordered, or prescribed by an excluded individual or
entity. https://www.sam.gov/portal/public/SAM/
https://www.sam.gov/portal/public/SAM/
Slide 52
Sanction Screening Who can be sanctioned? Individuals and
businesses/entities. Why? Default on health education loan or
scholarship obligations. Failure to meet statutory obligations of
practitioners and providers to provide' medically necessary
services meeting professionally recognized standards of health care
Conviction relating to patient abuse or neglect. Felony conviction
relating to health care fraud. Felony conviction relating to
controlled substance. Claims for excessive charges, unnecessary
services or services which fail to meet professionally recognized
standards of health care, or failure of an HMO to furnish medically
necessary services.
Slide 53
Sanction Screening CMS has further advised States that they
should require Medicaid providers to search the OIGs LEIE on a
monthly basis. In addition, states have independent legal authority
to exclude individuals and entities from participation in their
individual state Medicaid programs. Many states have developed
their own lists of sanctioned and excluded individuals and entities
that should be searched in addition to the federal OIG and SAM
lists. For example, the New York Office of Medicaid Inspector
General (OMIG) issues its own List of Restricted, Terminated, and
Excluded Individuals and Entities, and advises that health care
providers check the OMIG list, as well as the LEIE and SAM on a
monthly basis.
Slide 54
Sanction Screening Section 6501Section 6501 of the Affordable
Care Act states that if an individual or entity is excluded in one
state, then he/she or it, is excluded in all states. This means
that healthcare employers and companies need to make sure their
compliance program includes searching all available state Medicaid
exclusion registries as well as the federal exclusions lists.
Slide 55
States that have Medicaid exclusion registries: AlabamaMichigan
ArizonaMississippi Arkansas Nebraska California New Jersey
Connecticut Nevada District of Columbia New York Florida Ohio
HawaiiPennsylvania IdahoSouth Carolina IllinoisTennessee
KansasTexas Kentucky Washington MassachusettsWest Virginia Maryland
Wyoming Maine
Slide 56
Sanction Screening Require current employees to report to the
nursing facility if, subsequent to their employment, they are
convicted of an offense that would preclude employment in a nursing
facility or are excluded from participation in any Federal health
care program; and Regardless of the size or resources of the
nursing facility, employee screening is critical. Nursing
facilities, like all corporations, must act through their employees
and are held accountable for their actions.
Slide 57
Written Agreement with a Hospice Provider This final rule
specifies, for the facility, what the written agreement with the
hospice should address. It is important to note that not every
requirement of the new rule must be in the written agreement. Only
the following obligations set forth in 483.75(t)(2)(ii) are
specifically required to be included in the agreement:
Slide 58
Written Agreement with a Hospice Provider A.The services the
hospice will provide B.The hospices responsibilities for
determining the hospice plan of care C.The services the LTC
facility will continue to provide, based on each residents plan of
care D.A communication process, including how communication will be
documented between the LTC facility and hospice E.That the LTC
facility must immediately notify the hospice about: A.Significant
change in the residents physical, mental, social or emotional
status; B.Clinical complications that suggest a need to alter the
plan of care; C.Need to transfer the resident from the facility for
any condition; or D.Residents death
Slide 59
Written Agreement with a Hospice Provider I.That LTC facility
personnel may assist in the administration of prescribed therapies
when permitted by state law and specified by the facility. J.That
the LTC facility must immediately report all alleged violations
involving mistreatment, neglect, abuse, misappropriation of patient
property by hospice personnel to the hospice administrator. K.The
responsibilities of the hospice and the LTC facility to provide
bereavement to LTC staff.
Slide 60
Written Agreement with a Hospice Provider That the hospice
assumes responsibility for determining the appropriate course of
hospice care, including level of care A.The LTC facilitys role in
providing 24-hour room and board care to meet the residents
personal care and nursing needs, in coordination with the hospice
representative The hospices responsibilities for services,
including, but not limited to: Medical direction and management of
the patient Nursing Counseling (including spiritual, dietary and
bereavement) Social work Supplies, DME and drugs All other hospice
services that are necessary for the care of the resident's terminal
illness and related conditions
Slide 61
Resources AHIMA Documentation and Practice Guidelines Long Term
Care http://www.ahima.org/infocenter/guidelines/l tcs/index CMS
Certification and compliance
http://www.cms.gov/certificationandcompliance/ Office of the
Inspector General http://www.oig.hhs.gov Minimum Data Set 3.0
Training Materials http://www.cms.gov/nursinghomequalityinits/
Slide 62
Appendix P Survey Protocol Appendix PP Interpretive Guidelines
http://www.cms.gov/manuals SNF Pepper Users Guide First Edition
http://pepperresources.org/TrainingResources/Skill
edNursingFacilities
Slide 63
Hospice Services Provided in a Long Term Care Facility
http://www.nhpco.org/sites/default/files/public
/regulatory/Hospice_Nursing_Facility.pdf
http://www.nhpco.org/sites/default/files/public
/regulatory/NH_Comp-Final-Rule_July- 2013.pdf