Alternative Enforcement Sanctions for Home Health Agencies

The Centers for Medicare and Medicaid Services (“CMS”) issued a final rule that will implement, for the first time, a range of alternative sanctions against home health agencies (“HHAs”) found to have deficiencies constituting noncompliance with Medicare conditions of participation (“COPs”). The recording will cover:

Informal Dispute Resolution
The Alternative Sanctions
What Are the Alternative Sanctions and How Do They Work?
• Suspension of Payment for all New Patient Admissions and New Payment Episodes
• Directed Plans of Correction
• Directed In-Service Training
• Temporary Management
• Some Basic Rules You Need to Know About Alternative Sanctions
• Factors CMS Considered in Selecting Alternative Sanctions
Provider Appeals of Sanctions Imposed For Noncompliance
Lessons from the SNF World
CMS Next Steps & Monetary Penalties

Presenter: Kenneth L. Burgess, JD, Partner, Poyner Spruill
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