• How to Use PEPPER to Audit for Accurate Coding and Billing for Medicare Part

    By Liz Barlow, RN, CRRN, RAC-CT, DNS-CT - April 20, 2021

    The federal government focuses intently on preventing fraud, waste, and abuse within the Medicare system. As a part of those efforts, the Program for Evaluating Payment Patterns Electronic Report (PEPPER), initially released as a result of the Affordable Care Act, gathers data on billing patterns of skilled nursing facilities (SNFs) across the nation. In addition to their role helping the Centers for Medicare & Medicaid Services (CMS) identify improper payments, PEPPER reports can also guide facilities’ audits and compliance efforts.


    Read this article for tips for nurse assessment coordinators (NACs) on how to best utilize PEPPER.

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  • O0100: Learn Potential Coding Issues With This High-Impact MDS Item

    By Caralyn Davis, Staff Writer - April 20, 2021

    MDS item O0100 (Special Treatments, Procedures, and Programs) has 12 sections with two columns (24 total subitems) that identify specific services the resident received either while not a resident (column 1) or while a resident (column 2) during the 14-day lookback period.


    "These O0100 items play a significant role in two key areas of facility life beyond care planning," says Beckie Dow, RN, RAC-MT. Those areas are primarily payment and Quality Measures. Read this article to learn about some common problem areas with O0100 and how to avoid them.

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  • COVID-19: Renewal of Determination That A Public Health Emergency Exists (4/21)

    By HHS - April 19, 2021
    As a result of the continued consequences of the Coronavirus Disease 2019 (COVID-19) pandemic, on this date and after consultation with public health officials as necessary, I, Xavier Becerra, Secretary of Health and Human Services, pursuant to the authority vested in me under section 319 of the Public Health Service Act, do hereby renew, effective April 21, 2021, the January 31, 2020, determination by former Secretary Alex M. Azar II, that he previously renewed on April 21, 2020, July 23, 2020, October 2, 2020, and January 7, 2021, that a public health emergency exists and has existed since January 27, 2020, nationwide.
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  • National Healthcare Safety Network (NHSN) Long-term Care Facility COVID-19 Reporting Module Website UPDATED (4/21)

    By CDC - April 19, 2021

    CDC’s NHSN provides healthcare facilities, such as long-term care facilities (LTCFs), with a secure reporting platform for reporting outcomes and process measures in a systematic way. Reported data are immediately available for use in strengthening local and national surveillance, monitoring trends in infection rates, assisting in identifying resource insecurities, and informing progress toward infection prevention goals.

    The NHSN Long-term Care Facility Component supports the nation’s COVID-19 response through the LTCF COVID-19 Module. Facilities eligible to report data to NHSN’s COVID-19 Module include nursing homes/skilled nursing, long-term care for the developmentally disabled, and assisted living facilities.

    Data reported into the LTCF COVID-19 Module Surveillance Reporting Pathways facilitate assessment of the impact of COVID-19 through facility reported surveillance data. Examples of data reported in the pathways include:

    • Counts of residents and facility personnel newly positive for COVID-19 based on viral test results.
    • COVID-19 vaccination status of residents newly positive for COVID-19.
    • Re-infections in residents and facility personnel previously infected with COVID-19.
    • COVID-19 related death counts among residents and facility personnel.
    • Staffing shortages.
    • Availability and surge capacity use of personal protective equipment (PPE) and alcohol-based hand rub.
    • Monoclonal therapeutic availability and use.
    • Ventilator capacity and supplies for facilities with ventilator-dependent units.

    The Point-of-Care (POC) Test Reporting Tool is a separate reporting option for LTCFs to report SARS-CoV-2 test results provided by a POC device. NHSN routes reported POC laboratory test result data to the public health agency at the local or state level with jurisdictional authority and responsibility for receiving those data. Important: the reporting of POC test result data in this tool does not take the place of answering POC related questions in the Resident Impact and Facility Capacity surveillance reporting pathway.

    Weekly reporting of COVID-19 vaccination data for residents and healthcare personnel is another option available to LTCFs. Additional information about surveillance and vaccination reporting, please visit the Weekly HCP & Resident COVID-19 Vaccination webpage.

    LTCF data submission options include manual data entry, CSV file submission by individual facilities or bulk CSV file upload for multiple facilities, and/or NHSN DIRECT CDA Automation for the Point-of-Care (POC) Test Reporting Tool. Information about the Direct protocol can be found here. Send questions to NHSNCDA@CDC.GOV with Subject line “Direct Submissions for POC data.”

    For additional information about the LTCF COVID-19 Module, reporting options, data collection forms, form instructions, archived and upcoming trainings, and future updates, please review the resources on this page.

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  • FY 2022 SNF PPS Proposed Rule Puts the Spotlight on Quality Measures

    By Caralyn Davis, Staff Writer - April 17, 2021

    On April 8, the Centers for Medicare & Medicaid Services (CMS) released for public inspection the Fiscal Year (FY) 2022 Proposed Rule for the Skilled Nursing Facility Prospective Payment System (SNF PPS) and Consolidated Billing, and Updates to the Quality Reporting Program and Value-Based Purchasing Program (CMS-1746-P) as required by law. The agency will accept comments, which may be made electronically, through June 7.

    The FY 2022 SNF PPS proposed rule is a sweeping document that discusses specific proposals for FY 2022 and beyond, as well as new ideas that CMS is still beginning to formulate—with a heavy emphasis on future quality reporting.

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  • Medicare FFS Claims: 2% Payment Adjustment (Sequestration) Suspended Through December (4/21)

    By MX - April 16, 2021

    The Coronavirus Aid, Relief, and Economic Security (CARES) Act suspended the sequestration payment adjustment percentage of 2% applied to all Medicare Fee-for-Service (FFS) claims from May 1 through December 31, 2020.  The Consolidated Appropriations Act, 2021, extended the suspension period to March 31, 2021. An Act to Prevent Across-the-Board Direct Spending Cuts, and for Other Purposes, signed into law on April 14, 2021, extends the suspension period to December 31, 2021.

    Medicare Administrative Contractors will:

    ·         Release any previously held claims with dates of service on or after April 1

    ·         Reprocess any claims paid with the reduction applied

    You don’t need to take any action.  

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  • OIG to Look at SNF PDPM Reimbursement (4/21)

    By OIG - April 16, 2021

    The OIG will determine whether Medicare payments to SNFs under PDPM complied with Medicare requirements.

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  • Beta Test: JAVA PDPM Grouper (4/21)

    By CMS - April 16, 2021
    A beta test version of the Java PDPM Grouper has been posted. This version is to allow users to familiarize themselves with the Java program.  The Fiscal Year 2022 PDPM Grouper, v.2.0, will be distributed only in a Java version.
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  • Emergency Preparedness, Appendix Z, State Operations Manual (SOM) (4/21)

    By CMS - April 15, 2021

    On April 16, 2021, CMS issued a transmittal containing the finalized update to Appendix Z, Emergency Preparedness, of the State Operations Manual. Below is (1) The transmittal and (2) the original QSO memo announcing the update: 

     1. Revisions to the State Operations Manual (SOM) Appendix Z - Emergency Preparedness

    I. SUMMARY OF CHANGES: This Transmittal includes revisions based on recent federal regulation changes via (CMS–3346–F) and is a follow up to memo QSO 20-07 released on December 20, 2019. In addition to updates on the interpretive guidelines, this update also provides additional guidance on emerging infectious diseases. We are making changes to Appendix Z to reflect lessons learned and additional guidance related to pandemic preparedness as a result of the COVID-19 public health emergency.


    IMPLEMENTATION DATE: April 16, 2021


    2. QSO Memo # QSO-21-15-ALL

    Posting Date 2021-03-26

    Fiscal Year 2021


    Burden Reduction Final Rule Interpretive Guidelines: The Centers for Medicare & Medicaid Services (CMS) is releasing interpretive guidelines and updates to Appendix Z of the State Operations Manual (SOM) as a result of the revisions of the Medicare and Medicaid Programs; Regulatory Provisions to Promote Program Efficiency, Transparency, and Burden Reduction (CoPs) (CMS 3346-F) Final Rule.

    Expanded Guidance related to Emerging Infectious Diseases (EIDs): CMS is also providing additional guidance based on best practices, lessons learned and general recommendations for planning and preparedness for EID outbreaks.

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  • CMS QSO Memo: Some Expirations of COVID-19 Survey/Regulatory Waivers Begin May 10 (4/21)

    By CMS - April 09, 2021

    CMS continues to review the need for existing waivers issued in response to the Public Health Emergency (PHE). Over the course of the PHE, nursing homes have developed policies or other practices that we believe mitigates the need for certain waivers.

    • Therefore, CMS is announcing it is ending:
      • The emergency blanket waivers related to notification of Resident Room or Roommate changes, and Transfer and Discharge notification requirements;
      • The emergency blanket waiver for certain care planning requirements for residents transferred or discharged for cohorting purposes.
      • The emergency blanket waiver of the timeframe requirements for completing and transmitting resident assessment information (Minimum Data Set (MDS).
    • CMS is providing clarification and recommendations for Nurse Aide Training and Competency Evaluation Programs (NATCEPs).
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  • FY 2022 SNF PPS Proposed Rule Considers PDPM Parity Adjustment and Other Changes (4/21)

    By CMS - April 08, 2021

    Fiscal Year (FY) 2022 Skilled Nursing Facility Prospective Payment System Proposed Rule (CMS 1746-P) Fact Sheet

    CMS issued a proposed rule that would update Medicare payment policies and rates for skilled nursing facilities under the Skilled Nursing Facility (SNF) prospective payment system (PPS) for fiscal year (FY) 2022. In addition, the proposed rule includes proposals for the SNF Quality Reporting Program (QRP), and the SNF Value-Based Program (VBP) for FY 2022. CMS is publishing this proposed rule consistent with the legal requirements to update Medicare payment policies for SNFs on an annual basis. The major provisions of the proposed rule include the following:

    • FY 2022 Proposed Updates to the SNF Payment Rates  
    • Methodology for Recalibrating the PDPM Parity Adjustment
    • Rebase and Revise the SNF Market Basket
    • Section 134 of the Consolidated Appropriations Act, 2021  – New Blood Clotting Factor Exclusion from SNF Consolidated Billing 
    • Proposed changes in PDPM ICD-10 Code Mappings 
    • Skilled Nursing Facility Quality Reporting Program (SNF QRP) update
    • Closing the Health Equity Gap – RFI
    • Skilled Nursing Facility (SNF) Healthcare-Associated Infections (HAI) Requiring Hospitalization Measure
    • COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure
    • Transfer of Health (TOH) Information to the Patient-PAC Quality Measure
    • Public Reporting of Quality Measures with Fewer than Standard Numbers of Quarters Due to COVID-19 Public Health Emergency (PHE) Exemptions
    • Fast Healthcare Interoperability Resources (FHIR) in support of Digital Quality Measurement in Quality Reporting Programs – RFI
    • Skilled Nursing Facility Value-Based Purchasing (SNF VBP) Program
    • Proposal to suppress the SNF readmission measure in the SNF VBP Program
    • Expanded SNF VBP Program
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  • LTCSP Survey Resources: Surveyor Tools Updated (4/21)

    By CMS - April 08, 2021

    This ZIP file contains resources for surveyors conducting initial surveys under the Long-term Care Survey Process (LTCSP).

    04/08/2021 Survey resource folder

    1. Updated F tag waiver Guide
    • Crossed out waivers that have been terminated


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  • COVID-19 Blanket Waivers List Updated (4/21)

    By CMS - April 07, 2021

    COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers 

    The Administration is taking aggressive actions and exercising regulatory flexibilities to help healthcare providers contain the spread of 2019 Novel Coronavirus Disease (COVID-19). CMS is empowered to take proactive steps through 1135 waivers as well as, where applicable, authority granted under section 1812(f) of the Social Security Act (the Act) and rapidly expand the Administration’s aggressive efforts against COVID-19. As a result, the following blanket waivers are in effect, with a retroactive effective date of March 1, 2020 through the end of the emergency declaration. For general information about waivers, see Attachment A to this document. These waivers DO NOT require a request to be sent to the 1135waiver@cms.hhs.gov mailbox or that notification be made to any of CMS’s regional offices.

    Long-Term Care Facilities and Skilled Nursing Facilities (SNFs) and/or Nursing Facilities (NFs) 

    Updated April 9, 2021, the SNF/NF section now shows which regulatory waivers expire May 10, 2021.
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  • Beneficiary Notices Really Can Be Understood

    By Jane Belt, MS, RN, RAC-MT, RAC-MTA, QCP - April 06, 2021

    Although the Centers for Medicare & Medicaid Services’ (CMS) beneficiary notices have been part of Medicare regulations for a long time, they can still be cited during any survey. Lengthy discussions in the AANAConnect LTC - MDS Network community have explored beneficiary notices and highlighted areas of uncertainty. With new folks entering the world of long-term care (welcome!), it is a good time to provide an overview of the requirements and share where to find additional help on these notices.

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  • Observation and Assessment: Learn the Ropes of This Underused Skilled Service

    By Caralyn Davis, Staff Writer - April 06, 2021

    Observation and assessment of a resident’s condition is a skilled service under Medicare Part A that many nurse assessment coordinators (NACs) and Medicare case managers hesitate to use because it’s not a direct skilled nursing or skilled rehabilitation service. That, and applying CMS's definition of observation and assessment to real-world skilling scenarios can be confusing.


    In this article, read about steps NAC can take to make the process smoother.

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