Monday, August 21, 2017

CMS Provider Compliance Resources to Prevent Part A SNF PPS Denials

This week, the Centers for Medicare & Medicaid Services (CMS) Medicare Learning Network (MLN) Connects newsletter provided the following information and resource links for skilled nursing facilities (SNFs) to help prevent errors that commonly result in SNF Part A Prospective Payment System (PPS) payment denials:

According to the 2015 Comprehensive Error Rate Testing (CERT) Report, the denial rate for SNFs increased from 6.9 percent in 2014 to 11 percent in 2015 due to missing or incomplete certification/recertification:
      • Statement must contain need for skilled services that can only be provided in SNF/swing-bed on a daily basis for a condition patient was treated for in prior hospital stay
      • Must include physician’s dated signature (printed name if signature is illegible)

In addition, recertifications should include:
      • Expected length of stay
      • Explanation if continued need for services is for a condition that arose after SNF admission
      • Any plans for home care


Friday, August 18, 2017

Webinar: Preparing for the New Survey Process and RoP Phase 2

Webinar:Preparing for the New Survey Process and Requirements of Participation Phase 2
Date: September 25, 2017 – 1:00 pm – 2:00 pm Eastern 
Register Here

November 28, 2017 is a significant date for all nursing centers. That date marks the following:

(1) The implementation of Phase 2 of the Requirements of Participation (RoP)
(2) All new F-Tag numbers
(3) New interpretive guidance, and 
(4) A brand-new annual survey process. 

As a result, providers might be feeling anxious and overwhelmed.This webinar will provide information on what to expect in the new survey process; updates on materials available from the Centers for Medicare & Medicaid Services (CMS), AHCA tools and resources available to help you understand and implement new Phase 2 requirements such as the Facility Assessment, and guidance on how to access AHCA's tools and resources.

Learning Objectives:
1. Participants will review key elements of the new survey process and be prepared for the changes that will be implemented on November 28, 2017.

2. Participants will learn about tools and materials available from AHCA to help centers implement Phase 2 requirements and will understand how to access these resources on ahcancalED. 

3. Participants will understand the importance of using a framework focused on the intent and purpose of the requirements to help centers navigate successfully through these changes.

Sara Rudow, Director of Regulatory Services, AHCA
David Gifford, Sr. VP, Quality and Regulatory Affairs, AHCA
Bobbie Vailes, Manager ahcancalED, AHCA

Wednesday, August 16, 2017

Webinar: The Importance of Collaboration between Nurses and Environmental Services

August 21, 1:00 PM – 2:00 PM EDT

The Centers for Disease Control and Prevention (CDC) and the American Nurses Association invite you to register for a free webinar to learn how collaboration between nurses and environmental services prevents and reduces the spread of healthcare-associated infections. The speakers will cover the application of standards, guidelines, best practices, and established processes in infection control.

Breaches in cleaning and disinfection practices in the healthcare settings can be a significant factor in the transmission of healthcare-associated infections. Preventing contamination between the environment and patients is critical to breaking the chain of infection.

This webinar is hosted by members of the Nursing Infection Control Education (NICE) Network, including the Oncology Nursing Society, the National Association of Directors of Nursing Administration, and the American Association of Colleges of Nursing.

Therapy Professionals: Convention Offers Special Half-Day Program Just for You


Interdisciplinary Rehabilitation of Complex Patients in a
Value-Based Payment Environment

Hosted by:
AHCA and National Association for the Support of Long Term Care (NASL)

Back for a fourth year, AHCA and NASL bring you this important half-day session featuring the most current information on achieving outcomes and managing costs.

Beginning with a networking coffee reception, this targeted event will focus on:
·         Interdisciplinary approaches to assess the rehabilitation potential of complex patients
·         Strategies to more effectively restore function for those with restoration potential
·         Strategies to transition to skilled and non-skilled maintenance programs for individuals when functional improvement is no longer a realistic outcome

This is a separate ticketed event and must be purchased in addition to any convention registration package. If you have not yet registered for this year’s Convention & Expo, register today. The deadline is September 21.

If you have already registered for convention but would like to add the Rehab Therapy Program, go to registration, click Edit Registration, and sign in with your e-mail address. Then edit your registration package.

See you in Las Vegas!


Encore Rehabilitation

Aegis, Affirma, CEU 360, Consonus, Genesis, Therapy Management Corp, Rehabcare, and ONR

Don’t Gamble With Your Business

At AHCA/ NCAL Annual Convention & Expo, you’ll have two amazing days to build your professional network. It’s time you hit the networking jackpot. Come show your innovative technology that will help provide the best quality care in the industry.

"AHCA Convention allows me the opportunity to seek innovative products, programs and vendor sourcing for our chain efficiently. While allowing for valuable learning sessions from leaders and experts in our field."
– 2016 Convention Attendee 

Sen. Murkowski Visits AHCA Member Facility

Drew Thies

Senator Lisa Murkowski (R-Alaska) visited Prestige Care and Rehabilitation Center in Anchorage last week to hear from residents and speak about health care reform. Sen. Murkowski was one of three Republicans who voted against a bill to repeal and replace the Affordable Care Act, also known as Obamacare, late last month.

Sen. Murkowski highlighted the growing population of seniors in Alaska and spoke to their unique needs. She said that while she agrees health care reform efforts need to continue, the legislation brought to the floor in the Senate in July would have harmed Alaska’s seniors.

Sen. Murkowski stood alongside Sen. Susan Collins (R-Maine) as the only two members of the Republican party to oppose opening debate on repeal and replace efforts. Versions of this legislation would have cut billions from Medicaid funding for long term care services.

Both the Senate and House are in recess through the rest of the month and it is a great time for lawmakers to visit providers to learn more about long term and post-acute care. AHCA members who would like help coordinating a facility tour, are encouraged to contact Matt Smyth, AHCA’s Senior Director of Grassroots and Membership Advocacy at

Be Ready to Demonstrate Your Dementia Care Competency to Surveyors: Register for the Intensive AHCA/NCAL Convention Session on Implementing CARES® Online Dementia Training & Alzheimer’s Association EssentiALZ® Certification

Dave Kyllo

Administrators, directors, nurses and other long term care staff interested in quality dementia care are encouraged to register for a facilitated intensive training session led by national CARES® expert, Debbie Richman, to learn how to implement the CMS- and AHCA/NCAL-recommended CARES® online training program within your organization.  At the end of the training session, attendees will be eligible for individual Alzheimer’s Association essentiALZ® certification.

This unique learning opportunity at the 68th Annual AHCA/NCAL Convention and Expo in Las Vegas is back this year by popular demand.  Attendees will complete the CARES® Dementia Basics curriculum and learn about the training tools, techniques, and activities to implement the CARES® Approach within your organization utilizing the CARES® Classroom Guide™ for Administrators and Educators.  

This session is a great way to help skilled nursing centers develop dementia specific educational programs that can help demonstrate staff competency in quality dementia care as part of the new staff competency assessments that will be required under Phase II of the CMS Requirements of Participation taking effect this November.  Specialized training will be one way surveyors will determine if caregivers have the competencies necessary to deliver quality and individualized care.       
The CARES® content video-intensive and includes care vignettes and interviews of real people living with dementia, their families, professional caregivers, and dementia experts (no actors).  In addition, this session will offer unique networking opportunities to learn from your dementia care colleagues from across the nation.  

The CARES® Dementia Basics Training is approved for 5.5 Administrator CEUs will be held on Sunday, October 15 from 8 a.m. to 4 p.m. and is a separate ticketed event.  The registration fee for this special intensive training is only $199.95.  As an added bonus, attendees will receive a complimentary copy of the CARES® Classroom Guide™ for Administrators and Educators – a $199.95 value – which offsets the entire cost of the session. 

Click here to register for the AHCA/NCAL Convention and Expo held October 15 – 18 in Las Vegas.

The Number of Open LTC Jobs Dips Slightly in August

Dave Kyllo

There are 20,492 open jobs posted by direct employers this month in the nursing care facility (including SNFs), assisted living, and continuing care retirement community (CCRC) sectors this month according to the latest CEB TalentNeuron statistics.  The number of open jobs posted nationwide by direct employers decreased slightly since July.

The CEB TalentNeuron statistics also show an estimated 2,101,000 potential candidates in the nation’s workforce whose skills likely match the qualifications being sought by long term care employers Figures show that 2,065 direct employers are competing for candidates in July – an increase of slightly more than 100 employers.  The average number of days a job was posted this month held steady at 37.  

Finding qualified employees is one of the greatest challenges facing long term care providers.  The AHCA/NCAL Long Term Care Career Center is designed to help members be competitive in attracting qualified candidates to fill their health care job vacancies.  The LTC Career Center is also fully integrated with Google’s new job search feature “Google for Jobs” creating even greater exposure for job postings.

Rates for posting job vacancies are affordable and give prospective employers far greater exposure than local ads and job boards by connecting to a network of more than 330 national and state health care organizations and societies.   Employers are also able to post vacancies as they occur and search resumes on the network.

There are two great ways for skilled nursing center and assisted living employers to save on their job postings on the Long Term Care Career Center.  First-time job posters can receive 25% off their first posting by entering promo code New25off when they check out.  Employers with multiple positions to fill can purchase three job postings at one time and receive a 20% discount on the three postings by entering promo code Bundle20 at check out.

Of course, the LTC Career Center is always free for job seekers.  And, job seekers are using the site with more than 90,000 searchable resumes on the National Healthcare Career Network this month.   Job postings on the AHCA/NCAL Long Term Care Career Center network are averaging more than 1,500 views in August.

Employers who utilize the site also receive outstanding exposure through rotating job listings on AHCA’s home page – the web site where long term care professionals go for news and information.  In addition, employers who post vacancies through the center receive bonus rotating listings on the Long Term Care Career Center home page.

Be seen nationwide. Check out the LTC Career Center today and remember to use one of the two promo codes to save on your job postings.    

Three Reasons Why Nursing Facilities Should Train Their Infection Preventionists Now

Dave Kyllo

The American Health Care Association (AHCA)  is ready to help members meet the new Infection Preventionist specialized training requirement finalized by CMS in the Reform of Requirements of Participation for Long Term Care Facilities. This Infection Preventionist Specialized Training (IPCO) course provides education for healthcare professionals who seek to serve as Infection Preventionists. Individuals who complete the course will be trained to effectively implement and manage an Infection Prevention and Control Program (including antibiotic stewardship programs) at their nursing facilities.

Even though nursing facilities are not required to have a designated “Infection Preventionist” until November 2019, there are three compelling reasons why it is critical to register for this training now:

  • As of November 28, 2016 nursing facilities are being held accountable to more expansive infection prevention and control federal regulations. 
  • Beginning November 28, 2017, the federal requirements for nursing facilities expand further and require that every nursing facility develop and implement an antibiotic stewardship program. This is a new requirement that should be conducted with oversight from specially trained healthcare professionals. 
  • Surveyors nationwide are being trained this summer to survey for the expanded infection prevention & control and antibiotic stewardship requirements.

The course is an online, self-study program with 23 hours of training. It includes online lectures, case studies and interactive components taught by subject matter experts who have real life experience working in long term/post-acute care.  It addresses both clinical and organizational systems, processes and cultural aspects of infection prevention and control that are fundamental to effectively leading and administering successful infection prevention and control programs and antibiotic stewardship programs.   Upon successful completion of this program, participants will receive certificates including 23 ANCC contact hours.

The training course registration fee is $450 for AHCA/NCAL members and $650 for non-members.  There are no refunds and no transfers.  Payment and registration must be made online in ahcancalED. The IPCO course can be accessed here or at:  

Discounted group purchase rates are available for groups of 25 or more.  Those interested in making a group purchase should email AHCA at  

To access ahcancalED and the IPCO course, members will need to login with their AHCA/NCAL usernames and passwords.  For assistance obtaining AHCA/NCAL usernames and passwords, please e-mail with your name and facility contact information.

Monday, August 14, 2017

CMS Posts Updated Part B Therapy Coding Scrutiny Starting January 2018

Dan Ciolek

Recently, the Centers of Medicare and Medicaid Services (CMS) posted a MLN Matters article (MM10176) titled “Updated Editing of Always Therapy Services -MCS.”  The article, intended for providers of Part B therapy services, identifies outpatient therapy procedures that must always be accompanied by a discipline-specific therapy modifier (GP = physical therapy, GO = occupational therapy, and GN = speech-language pathology services).

CMS also notes that per CR10176 instructions, they are requiring the Medicare Administrative Contractors (MACs) to update their claims-processing systems edits, as follows for services furnished on or after January 1, 2018:

  • MACs will return/reject claims which contain an “always therapy” procedure code, but do not also contain the appropriate discipline-specific therapy modifier of GN, GO, or GP. 
  • MACs will also return/reject claims if any service line on the claim contains more than one occurrence of a GN, GO, or GP therapy modifier. 
  • MACs who are returning/rejecting such claims will use Group Code CO and Claim Adjustment Reason Code (CARC) 4 on the related remittance advice.

The complete code list that this policy will apply to in CY 2018 will be posted later this year on the CMS Annual Therapy Update web page at

In addition, while many of these codes can be used by any of the three therapy disciplines, CMS notes that several “always therapy” codes have been identified as discipline-specific – requiring the GN modifier for six codes, the GO modifier for four codes, and the GP modifier for four codes, as illustrated in Tables 1-3 below.

AHCA recommends that SNF billers review this guidance.  If you have questions, contact Dan Ciolek, AHCA Associate Vice President, Therapy Advocacy.

Table 1: Codes Requiring the “GN” Therapy Modifier
CPT Short Descriptor
Therapy Modifier Required
Evaluation of speech fluency
Evaluate speech production
Speech sound lang comprehend
Behavral quality analys voice
Oral speech device eval
Ex for speech device rx 1hr

Table 2: Codes Requiring the “GO” Therapy Modifier (NEW CODES for 2018)
CPT Short Descriptor
Therapy Modifier Required
Ot eval low complex 30 min
Ot eval mod complex 45 min
Ot eval high complex 60 min
Ot re-eval est plan care

Table 3: Codes Requiring the “GP” Therapy Modifier (NEW CODES for 2018)

CPT Short Descriptor
Therapy Modifier Required
Pt eval low complex 20 min
Pt eval mod complex 30 min
Pt eval high complex 45 min
Pt re-eval est plan care