HELP WHERE HOSPITALS NEED IT ®
HELP WHERE HOSPITALS NEED IT ®
Community Hospital Blog
by April Myers, SVP Post-Acute Operations
It’s gratifying to see first-hand how patients with critical and complex needs improve—thanks to long-term acute care hospitals or LTACHs.
And now, since the Moratorium restricting LTACHs officially ended on September 30, 2017, more patients will have greater availability to be cared for in the specialized care setting of an LTACH. With the Moratorium sunset, LTACH growth opportunities are expected to blossom.
Patient success stories abound. One example shared with me about a patient at one of CHC’s 11 LTACHs is particularly memorable. A gentleman in his 40s experienced a fall at home. Arriving at the Emergency Department, he was placed on a ventilator and spent several days in the ICU; his prognosis was guarded. Subsequently, he was transferred to a CHC LTACH, weaned off the ventilator, and returned home with support from home health care services. Later, accompanied by family members, he returned to personally thank caregivers for the care he received.
Approximately 437 Medicare-certified LTACHs exist across the country, operating as a hospital within a hospital, a hospital satellite, or as a freestanding model. But over the past several years, new rules and qualifiers for admission have been imposed by the Centers for Medicare and Medicaid Services.
At CHC, we advocate on behalf of LTACHs and the ability to serve LTACH patients, many of whom are on ventilators, have gone through a great deal of trauma, and need extended hospitalization beyond a short-term acute-care hospital stay.
Our unique model and multidisciplinary approach to care for optimal recovery—all customized to the individual patient and with family input—supports the LTACH as an essential component of the patient care continuum.
LTACHs supplement the services provided by acute-care hospitals, extending patient care. Key characteristics of this care setting:
Fully-integrated LTACHs not only extend the continuum of care, hospitals and healthcare organizations benefit through cross-utilization of services and resources.
As part of its Post-Acute Care services, CHC currently owns 11 LTACHs in the states of North Carolina, South Carolina, Kentucky and Texas. Read more about CHC’s approach to long-term LTACH success.
Guest blog by Audrey Smith, Critical Access Hospital Coalition Executive Director
Since 2010, 81 rural hospitals have closed in the United States with another 673 at risk, endangering the health of individuals, families, and communities. Nearly 30 million people don’t live within an hour of trauma care. In fact, residents living in 16% of the mainland United States are 30 miles or more away from the nearest hospital. The rate of accidental deaths adjusted for age was nearly 50% higher in rural versus urban areas from 1999 to 2015 according to a CDC study, which also noted that long travel distances to specialty and emergency care placed residents at higher risk of death.
In response to rural hospital closures in the 1980s and early 1990s, the Critical Access Hospital (CAH) designation was created by Congress as part of the 1997 Balanced Budget Act, designed to reduce the financial vulnerability of rural hospitals and improve access to healthcare by keeping essential services in rural communities. Eligibility requirements for CAHs include 25 or fewer acute care inpatient beds; another hospital must be located more than 35 miles away; the facility must maintain an average length of stay of 96 hours or less for acute care patients; and the hospital must provide 24/7 emergency care services.
Today, Critical Access Hospitals are in 45 states. Many of these hospitals are the largest employer in their community, and each offers services and programs customized to area residents’ needs. For example, one hospital partners with their state government to provide vaccinations to children, another offers hip replacement surgery, and yet another conducts surgery for patients using the latest robotic equipment. Local rural hospitals develop very close relationships with their patients, providing hands-on care. One CAH executive shared with me how their hospital employees pushed an elderly patient in a wheelchair through the snow from a nearby clinic for care.
Despite having CAH designations, cuts to reimbursements and potential federal policy modifications, including proposed changes to Medicaid, intensify rural hospitals’ risk of closure. With 1 out of 5 people living in rural areas, CAHs serve a vital role in the health of their communities.
The Critical Access Hospital Coalition advocates on behalf of vulnerable CAHs located throughout the United States by proposing policy changes and regulatory adjustments that would benefit these essential facilities. Recently, in the wake of Hurricane Harvey, the Centers for Medicare and Medicaid Services announced that it will waive certain requirements for hospitals providing care, allowing lengths of stay beyond the capped 96-hour period and waiving the 25-bed limit for CAH designation. This type of relief is welcome to CAHs and rural communities.
About the Critical Access Hospital Coalition
The Critical Access Hospital Coalition (CAH Coalition) is a consortium of innovative healthcare leaders representing CAHs nationwide. Its sole purpose is to assist policy makers in understanding the unique needs of CAHs so that quality healthcare is sustained in rural communities. For more information, visit the CAH Coalition website.
by Melvin Ostlie, CHC Director of Information Technology
One line-item expense in every hospital budget regardless of facility size or location is telecommunications. Why do rural hospitals tend to pay more for telecom services than their urban counterparts? Carriers are able to charge for the expense of installing and maintaining communications to rural areas. Fortunately, reduced rates for broadband and telecom services are available to rural providers through the Rural Healthcare Telecommunications (RHC) Program, a federal program supporting universal service and access throughout the country. It includes two subprograms, the Healthcare Connect Fund (HCF) Program and the Telecommunications (Telecom) Program.
It’s easy to see why the program has become so popular with rural hospitals. In fact, due to a high demand for RHC Program funds in Funding Year 2016 (FY2016), the funding limit cap of $400 million was reached, and a second filing window – a fixed period when all funding requests received are treated as though they were received at the same time – was closed. In 2017, new funding requests were accepted under a revised filing window period from March 1 to June 30, 2017. Given this demand, the review process to obtain funding is more discriminating than ever before.
Also, effective January 1, 2017, Skilled Nursing Facilities (SNFs) came into the mix. SNFs can now begin the process to obtain RHC Program funding by applying as an individual health care provider.
Along with a tighter review process, hospitals need to ensure that everything is laid out in the way and language that funders want. That’s where CHC Consulting comes in. Our experts know what systems and equipment qualify and understand the filing process, helping hospitals access telecom savings ranging from 60 to 90 percent.
How CHC Consulting can help
To meet provider needs and enhance funding opportunities, CHC Consulting offers customized support, including:
For more information
See Telecommunications and USAC to discover how CHC can help your facility save money on telecom expenses.
By Amy Boykin, CHC SVP of Quality, Patient Safety and Care Management
Hospital accreditation is considered a standard of excellence for safe, high-quality care. Accreditation helps organize and strengthen patient safety efforts, improves risk management and risk reduction, and provides deeming authority for Medicare certification.
Mock surveys are a best practice to keep hospitals in a “stay ready” mode for an actual survey from a state survey agency on behalf of the Centers for Medicare and Medicaid Services (CMS) or accrediting organizations such as The Joint Commission or the Center for Improvement in Healthcare Quality (CIHQ). The good news – proactive community hospitals are following the practices of larger healthcare systems and implementing a mock survey process. Simply, it’s an industry best practice.
Mock surveys conducted every 12 to 18 months are a valuable component of quality improvement initiatives. This process provides a “snapshot” of compliance before an actual survey, while helping to teach, train and educate leaders and staff members. The goal is to improve care and patient care processes.
Like actual CMS certification or accreditation surveys, mock surveys are often unannounced and can be conducted by an outside consulting firm. Community Hospital Corporation conducts mock surveys for its owned and managed hospitals, involving a team of generally three to five “CHC surveyors.” Onsite at the hospital, the mock survey team conducts a review following guidelines outlined by CMS or the accrediting organization. Following the mock examination, CHC reviewers address hospital leaders personally in a verbal debrief. Within two weeks, the hospital receives a written report summarizing any deficiencies and recommendations for an action plan for improvement. Also, after a hospital goes through its actual survey, CHC compares the mock survey report to the final report from the accrediting organization to see how recommendations align.
Here are some insights and best practice tips for mock surveys.
CHC Consulting also provides mock surveys for consulting hospital clients upon request. For more information on mock surveys, including how this process dovetails with a hospital’s Compliance Program described in last month’s CHC blog, see CHC Clinical Quality services.
By Doug Kent, CHC VP Internal Audit/Compliance Officer
As healthcare becomes more complex, there is also more emphasis being placed on financial considerations, and on preventing and detecting violations of state and federal healthcare laws. What can your hospital do? Start by creating a compliance program to self-police your hospital and staff activities.
Since its inception in 1976, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) has led the charge to fight waste, fraud, and abuse in Medicare, Medicaid, and more than 100 other HHS programs. In 2010, as part of the Affordable Care Act, OIG mandated that all healthcare providers have a Corporate Compliance Program in place as a condition of enrollment for Medicare, Medicaid, and Children’s Health Insurance reimbursement.
Along with assuring that needed dollars go to patient care, compliance programs serve to engage and inform employees and community members that your hospital is committed to “doing the right thing.” It’s also key to have compliance policies in place should you ever face regulatory review or inquiry.
Here are some best practice recommendations to develop or enhance your hospital compliance program.
1. Assemble a compliance committee representing a cross-section of employees. Compliance “belongs” to everyone. It’s a team effort and extends beyond the role of the designated compliance manager or leader. C-suite members, case management, revenue cycle, IT/security, and other employee representatives should serve on your compliance committee. Establish a group charter, meet at least quarterly, and ensure confidentiality of information shared with this group.
2. Develop a robust education and training program. Provide compliance education/information as part of new employee orientation. Offer online education courses to meet yearly training requirements on topics including billing and collections, Medicare rules, HIPAA, compliance issues, EMTALA, and conflicts of interest.
3. Establish a compliance hotline. Make sure employees know the hotline is an anonymous reporting system assuring the confidentiality and protection of individuals who may come forward; communicate the purpose of this hotline (it’s not an employee “complaint” line).
4. Include sanction screenings in your compliance plan. The hospital is required to check state and federal exclusion lists monthly to identify if employees, contractors or third-party vendors have had adverse actions taken against them by federally funded programs. Screenings demonstrate you have a routine process in place to monitor potential compliance issues.
5. Define and document conflicts of interest. To protect patients’ well-being and ensure public trust, board and management team members should sign a conflict of interest statement as part of the compliance plan. Keep these documents on file.
6. Manage compliance risk issues through ongoing monitoring and auditing. Make sure your compliance work plan includes a continuous control process to keep current on changes in rules, regulations and laws. Your work plan should outline internal controls to comply with these guidelines. For auditing, the approach is more proactive. Steps could incorporate chart review to examine how codes are being used and applied, or charge tracking for certain procedures or supplies.
7. Measuring compliance programs. It’s important to measure the effectiveness of your existing hospital compliance program. Authorities recommend that you conduct an internal evaluation yearly to assess your program’s effectiveness, and an external audit every other year with a report back to you that outlines program improvements.
For additional compliance education materials see the OIG Compliance 101 resources.
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