Does the HCCA (or will the HCCA) involve themselves in the open discussion period? Since this is a proposed rule, their commentary may be influential. In addition, I wonder if HCCA is working directly with AHCA.
I was discussing this with another CO last week (Yolunda!) and we went line by line through the Federal Register. There are a couple of things that operationally will help SNF's. Resources are scare and reducing that burden in specific areas will be useful. For example, changing review of the compliance plan to every 2 years versus one. This is probably pretty reasonable and lightens the operational burden. However, there a couple of proposed changes that are awkward at best in their wording and they leave an unsettling impression that you have pointed out. If operations 'interprets' this guidance as a means to reduce costs via reducing the compliance department I think they will quickly find themselves out of sync with the intentions of the OIG. And with the source document being referenced in the federal register, it's hard to argue that those rules don't apply. But interestingly, the proposed rules would put the survey process out of alignment with those same guidelines.
One of my thoughts was that this proposed change was in small part due to CMS having difficulty creating a functional survey pathway for state surveyors. Our state surveyors have been honest throughout the phased implementation (as this compliance part was coming) that they were not appropriately trained and had concerns over how they would survey this regulation. They have been awaiting CMS guidance for this piece for quite some time.
I do hope that HCCA has SNF compliance officers working with AHCA. Each setting is unique and SNF always presents some interesting challenges. I had seen this phase 3 implementation as a beginning to cement the importance of compliance in the SNF. I would hate to lose that opportunity.
Just some thoughts.
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Bethanne VanderMolen
Chief Compliance Officer/Director of Risk Management
Choice Health Management Services, LLC
HICKORY,NC
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Original Message:
Sent: 07-19-2019 10:46 PM
From: Barbara Naimark
Subject: HEADS UP! Check the Fed Reg!
Joseph - you are absolutely right. I have worked hard for the last 6 years promoting that LTC needs compliance and all its resources. I'm hoping they will reconsider some of the proposed changes and the value of compliance in the LTC sector will not become a minor player.
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Barbara Naimark
Compliance Official
Collington
Severna Park,MD
Original Message:
Sent: 07-18-2019 08:13 AM
From: Frank Ruelas
Subject: HEADS UP! Check the Fed Reg!
For those who I taught how to check the Fed Reg and you work for a LTC...today is a good time to check the Fed Reg...if you are not doing so daily. There are some proposed rules that are directly related to compliance programs.
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► Week 4 of the 66ers...Sessions Coming Up! ◄
--------Frank Ruelas---------
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