As part of its survey process, the Centers for Medicare & Medicaid Services is authorized to take several enforcement actions, including but not limited to imposing civil money penalties (CMP), denials...
Does the Quality Assurance Privilege even exist after CMS’ new guidelines?
By
Alan C. Horowitz, Esq., RN
Feb 13, 2019
Anyone who has not yet read the Centers for Medicare & Medicaid Services’ recent guidelines for surveyors may be in for an unpleasant surprise.
Justice delayed is justice denied — especially in skilled nursing
By
Alan C. Horowitz, Esq., RN
Aug 09, 2022
Let’s try a little thought experiment. Imagine you are the owner or operator of a skilled nursing facility. Or, you are the director of nursing, administrator, therapist, nurse aide or physician. ...
CMS posts alleged deficiencies on Nursing Home Care Compare
By
Alan C. Horowitz, Esq., RN
Jan 25, 2023
The Centers for Medicare & Medicaid Services conveys its policies (and directives) through its Quality, Safety & Oversight (QSO) memos. On Jan. 18, 2023, CMS announced that beginning on Jan. 25, 2023,...
Attorneys general seek greater punishment for nursing homes: A counterproductive approach?
By
Alan C. Horowitz, Esq., RN
Jun 27, 2018
At the end of May, attorneys general from 16 states and the District of Columbia signed a letter to HHS Secretary Alex Azar urging him “to reconsider this regulatory rollback.” The “rollback” the...
Old wine, new bottles: Increased scrutiny for antipsychotic drug use
By
Alan C. Horowitz, Esq., RN
Feb 22, 2013
The landmark legislation known as “OBRA ’87” (the Omnibus Budget Reconciliation Act of 1987) significantly limited the inappropriate use of antipsychotic drug use in long-term care facilities....