Volume #07-2018 | July 2018
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Office of Inspector General
Division of Health Care
Long Term Care Provider Newsletter
July 2018
Hello All,

I hope everyone is having a lovely summer and that you have been able to take a little time off to enjoy the world away from work. Things are still busy, busy, busy at the OIG, and I am sure it is the same for you. 

Today, I want to take a moment and update you on a significant change within the OIG. The Cabinet is working to improve provider “on boarding” and recently underwent a reorganizational effort that resulted in the dissolution of the Office of Health Policy and OIG absorbing the certificate of need program. The OIG now has a fourth division, Division of Certificate of Need, under the leadership of our new Deputy Inspector General, Molly Nicol Lewis. Molly’s background is in healthcare law and she most recently served the Cabinet as Executive Director of the Office of Health Policy. We are delighted to have Molly and the CON staff of Laurie Walston, Michele Bushong, Elizabeth Tutt, and Sheena Eckley in the OIG and believe that this move will help us to better coordinate the CON and healthcare licensing programs for our providers.

As some of you may know, Jamie Gitzinger has joined our office, and is now working extensively to improve and expand our Civil Money Penalty Fund Grant Program. One of our goals is to provide some free training from subject matter experts for all certified LTC nursing facility providers on topics of interest to you. Our goal is to find people who can assist providers with concrete and specific tools to help your staff provide the highest quality care and also maintain compliance with regulatory requirements. 

We have some ideas for topics, but would love to hear your thoughts and ideas about things for which you would like to have in-depth training. We know the enormity of the task of providing quality care to your residents who are facing so many challenges, and we would love to provide some helpful, high quality, and free training to you through the CMP fund grant program to make your jobs easier. I have enjoyed providing training sessions on regulatory requirements in the past, but I am not a subject matter expert in most fields, and would like for you to benefit from the expertise of someone who has worked in, researched, and studied a particular area of care. So, PLEASE, let us hear from you regarding your needs and desires for training.


Take care, and, as always, thank you for all that you do on a daily basis.
                                                                               
Sandra Houchen, Director

Mid-Year Updates on RoPs and the New LTCSP
By Sandra Houchen

It is hard to believe that almost 8 months have passed since the Phase II nursing facility regulations went into effect and the new survey process was initiated. This article will discuss a few insights that have been noted since these changes were put into place.

First, let’s discuss the new survey process. We have had feedback from providers that they like the process, and feel it is going well. Surveyors, for the most part, also like the process. A few surveyors, who, like me, prefer to have physical paper and a clipboard in hand, are not as thrilled about the totally computerized process. But, we will have to be dragged kicking and screaming into the computer age whether we like it or not, as that is where the world is going.

There has been one unanticipated outcome since the new survey process has been initiated. Initial feedback from CMS on average numbers of deficiencies per survey show that Kentucky averages have significantly decreased in surveys conducted under the new process versus under the old process. While providers may welcome this change, it is something that we need to evaluate to determine what may be contributing to this outcome. There may be additional training needs for surveyors related to how to use the automated process effectively or there may be the need to evaluate on-site hours or survey team numbers. While we certainly are never looking for reasons to cite more deficiencies as we are already overwhelmed with the workload we do have, if there are clear violations of regulatory requirements, it is our job and duty to cite them. I am sure that each of you in the provider community can understand and appreciate that we all have our individual jobs that we strive to do to the best of our ability, and can understand why we need to evaluate and address this significant change in citation rates under the new survey process.

Successful Communication with Alzheimer's Patients
One of the most challenging aspects in caring for the Alzheimer's patient involves effectively communicating with the individual, especially as the disease progresses into its more latter stages. The caregiver's skill in communication is essential in interpreting the individual's needs and in promoting or maintaining his/her quality of life.
 
The Alzheimer's Association has developed a pamphlet titled  Communication , consisting of tips for successfully communicating with Alzheimer's patients during all stages of their disease process. The pamphlet is a concise resource that should be of value to caregivers and families alike in improving the care for patients with Alzheimer's, and we greatly appreciate the association's permission to share it with the readers of this month's provider newsletter.  
KEPRO Patient Navigation Program
For Medicare beneficiaries, understanding their doctor and making their way through difficult medical systems and treatments can be very overwhelming. KEPRO's free Patient Navigation program can help people with Medicare be a partner in and take control of their own health. KEPRO's Patient Navigators can work 1-on-1 with Medicare beneficiaries to:

  • Help coordinate care
  • Offer tips on how to manage medications
  • Help better understand a diagnosis or treatment plan
  • Provide resources and information to help patients understand, treat, and prevent diseases
  • Help improve quality of life

The following is an example of how the Patient Navigation program works. In this example, a Medicare beneficiary was discharged from a rehabilitation facility under the care of his wife after a brain bleed. His wife requested that he join the Patient Navigation program after his appeal was denied. He was able to walk with a front-wheeled walker, although he was independent before his hospitalization. His discharge plan was for home health, and he had no medical equipment at home. He had an upcoming visit with his primary care physician, and his wife was unsure how she would transport him.

KEPRO's Patient Navigator was able to assist the wife with setting up transportation for the doctor's appointment. The Patient Navigator also followed up with the home health agency, as the wife needed additional medical equipment, such as a shower chair. The Patient Navigator followed and assisted this beneficiary for 32 days to make sure there were no further needs and that he was progressing well with the home health agency.

KEPRO's Patient Navigation program is available for Fee-for-Service (FFS) Medicare beneficiaries. This program is part of their benefits from Medicare and is offered at no cost to them.

Please encourage your FFS Medicare beneficiaries to contact KEPRO for their healthcare navigation needs. For more information about KEPRO's Patient Navigation program, please visit

For assistance or more information, please contact Andrea Plaskett, Outreach Specialist, at  Andrea.Plaskett@bfcc2.hcqis.org.
KY Hepatitis Connection Newsletter
The  July edition of the KY Hepatitis Connection Newsletter  is dedicated to Dr. Robert Brawley, who served as the Chief of Infectious Disease at the Kentucky Department for Public Health for over 12 years. His expertise and guidance will be missed.

In addition to the newsletter, please see the attached  HCV Perinatal Poster Presentation  which was presented at CSTE in June 2018.

We hope you enjoy this Hepatitis Connections edition!

Kathy, Amanda, and Deb
SNF Service Termination Review Compliance
Skilled nursing facility service terminations are one of the highest volume reviews at KEPRO. With that in mind, what can your facility do to help make for a smooth review process? Listed below are some of the top reasons for Beneficiary and Family Centered Care Quality Improvement Organization (BFCC-QIO) denials:

1. The medical record documentation doesn't support the discontinuation of skilled services; and 

2. The Notice of Medicare Non-Coverage (NOMNC) is invalid for a number of reasons including:

a. failure to provide a two-day window between the signature/delivery date and the Effective Date

b. no signature on the NOMNC

c. if telephonically delivered, lack of annotation on the NOMNC or within the medical record to indicate that the organization called the representative and verbally delivered the NOMNC.

The Centers for Medicare & Medicaid Services (CMS) provides instructions for the issuance of the NOMNC as well as provides healthcare organizations with a copy of the appropriate NOMNC and Detailed Explanation of Non-Coverage (DENC) to be used. For official language, please go to: http://tiny.cc/CMSbni . As a general statement, skilled nursing facilities are required to provide a NOMNC to Medicare beneficiaries when their Medicare-covered service(s) are ending. The NOMNC informs beneficiaries how to request an expedited determination from KEPRO and gives beneficiaries the opportunity to request an expedited determination. A DENC is given only if a beneficiary requests an expedited determination and provides the organization or Medicare Advantage plan with the opportunity to explain their rationale for ending the Medicare-covered service(s).


For assistance or more information, please contact Andrea Plaskett, Outreach Specialist, at  Andrea.Plaskett@bfcc2.hcqis.org.

Bedrail FAQs
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CMS has provided answers to several frequently asked questions regarding bedrails, such as "Are all bedrails considered to be physical restraints?" These answers may be viewed  here .
A Message from Kentucky's QIN-QIO
The Office of Inspector General is pleased to provide information from the CMS funded QSource and atom Alliance, the Quality Innovation Network (QIN) - Quality Improvement Organizations (QIOs) for Kentucky. 
 
Click the link below to read a message from Kentucky's QIN-QIO:
 

MDS 3.0 Technical Information
A revised DRAFT version of the 2018 MDS item sets (v1.16.0R) was posted. This version contains a revision to discharge goal coding instructions in GG0130 (Self-Care) and GG0170 (Mobility), the addition of skip pattern language to GG0170M and GG0170N, revisions to skip pattern language to GG0170Q1 and GG0170Q3, the addition of coding instructions to J2000 (Prior Surgery), revisions to skip pattern language to M0210 and M0300G, and the addition of coding instructions to N2001 (Drug Regimen Review) and N2005 (Medication Intervention). This version is scheduled to become effective October 1, 2018. The files are located in the Downloads section of the website below.
 
ePOC Accounts
Is your facility signed up for ePOC? If so, be diligent about keeping your account and password up to date.  Click here  for the CMS security rules.

If your facility is not signed up, see the  Account Setup  instructions.

Not sure if your facility has any ePOC accounts or have other questions? E-mail  ePOC.Support@ky.gov .
TRAINING SECTION
COMING SOON - MDS Training
In collaboration with Myers and Stauffer LC, OIG-DHC is once again offering a free educational opportunity for LTC Providers this fall, which has been tentativelyscheduled for the dates below:
MDS 3.0 TRAINING

October 17-18, 2018

(More details will be available in future newsletters.)
Have you notified your residents?

Click the link below to download and/or print the contact list for various agencies.

to find an Ombudsman


Which Enforcement Branch
is Serving You? 
 
To provide the highest level of service, the Division of Health Care operates through four regional offices. Knowing the appropriate Enforcement Branch to contact with questions and concerns will ensure you receive maximum service in minimum time. Review links below for detailed information.

 
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CMS Survey and Certification memoranda, guidance, clarifications and instructions to State Survey Agencies and CMS Regional Offices.
 


Transfer/Discharge Hearing Appeals

Please submit your requests for transfer/discharge hearing appeals to Secretary Adam M. Meier, Cabinet for Health and Family Services, by emailing:


LTC Facility Self-Reported
Incidents & Complaints
    
New email addresses have been established for communications regarding LTC Facility Self-Reported Incidents and for use by residents and the general public to report possible violations of regulatory requirements.  Click Here  for the email addresses and additional contact information. 
ISTW: Integrated Surveyor Training Website

This CMS website provides training information to include the preceptor manual, the State Operations Manual and other documents. As always, the survey and certification process is a collaborative effort between CMS and providers. This website will allow providers the opportunity to take the same courses as surveyors.

5stars
NURSING HOME COMPARE
 


 Kentucky's Top 10 Citations for Nursing Homes



MDS/RAI CONTACT INFORMATION
 
Buffy Stone 
MDS Assessment/Coding
 502-595-4958 x.5019
or  e-mail  
   
Rhonda Littleton-Roe 
Transmission or Technical
502-564-7963 x.3300
or  e-mail


Employment Opportunities  

To search and apply for positions within the Office of Inspector General, please visit the Career Opportunities System webpage by clicking below.





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Inspector General 

Deputy Inspector General 


Assistant Director 
 
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Commonwealth of Kentucky | Office of Inspector General | 275 East Main St., Frankfort, KY 40602