Home Health Intermediate Sanctions: Everything Changed on July 1

This webinar will discuss CMS alternative sanctions for home health agencies and the considerations for CMS imposing these sanctions. It will cover types of sanctions available to providers, how sanctions are imposed, information dispute resolution (IDR), how to obtain an IDR, how an IDR differs from an appeal and much more. It will also discuss incorporating survey and certification issues into your compliance program as a means to avoid citations.

Why Should You Attend:

In 2011, CMS announced it was exercising its authority to implement alternative sanctions for the home health survey process. On July 1, 2014, the final element of those sanctions goes into effect. For the first time, home health providers will be exposed to the potential of civil monetary penalties and payment suspensions for condition level survey violations. Although these sanctions are supposed to be a way to get providers to achieve compliance without termination, the reality of payment suspensions and daily fines may be much worse.

Another important consideration is what remedies a provider can implement when sanctions are imposed. The regulations provide two options: information dispute resolution and appeals.

This webinar on CMS intermediate sanctions will:

• Introduce each of the available sanctions and which ones historically have been used most frequently by CMS.
• Review both the Immediate Jeopardy requirements and the more traditional condition level sanctions.
• Discuss the considerations for CMS imposing sanctions.
• Review the regulatory requirements for increasing or decreasing sanctions on a resurvey that finds continued non-compliance.
• Explain information dispute resolution (IDR), how to obtain an IDR and what relief it may provide.
• Discuss strategy consideration of using the IDR and how an IDR differs from an appeal.
• Review the requirements related to a formal appeal and how appealing impacts the process.
• Explore the option to waive your right to an appeal in exchange for a discount of the penalty amount.
• Focus on the most common survey mistakes agencies face. It will consider survey preparation and responding to surveyors. Finally, it will discuss incorporating survey and certification issues into your compliance program as a means to avoid citations.

Areas Covered in the Webinar:

• CMS authority to impose alternative sanctions
• Types of sanctions available to providers
• How sanctions are imposed, how sanctions are lifted
• What is a repeat finding and how does it impact sanction decisions.
• Clarification on sanctions from CMS
• What does the nursing home industry's experience tell us?
• What is an IDR
• How the IDR process will impact providers
• Providers right to appeal
• How survey compliance is more important than ever
• How to incorporate survey compliance into your compliance program.

Who Will Benefit:

• Administrators
• Director of Nursing
• Owners
• Executives