Regulatory

Gavel on BookMHA’s staff interacts with federal and state officials to shape the regulatory activities of many federal and state agencies. This involves analyzing rules and regulations proposed by federal and state agencies and providing comments, where appropriate.

Medicaid

Health providers participating in Missouri’s Medicaid program, known as MO HealthNet, serve the health care needs of low-income children, their parents and caregivers, as well as the health care, nursing home and in-home care needs of the elderly and disabled.

Medicare

Hospitals that serve as Medicare providers must adhere to various rules and regulations for patient care and reimbursement. The following offer guidance to hospitals to ensure their compliance with Medicare.

  • Streamlining Government Initiative
  • Federal Regulations
  • State Regulations

To ensure Missourians receive quality and affordable health care, MHA is soliciting member input on actions to streamline existing regulatory requirements, and eliminate duplicative, obsolete or unnecessary state regulatory burdens.

Tell us about any requirements that you think can be performed in a more efficient manner by emailing Ted Wedel or Daniel Landon.

 

CMS Issues Revision To Appendix W For CAHs

The Centers for Medicare and Medicaid Services have issued Survey and Certification Memo 17-10-CAHs, which revises the staffing requirements for emergency care in critical access hospitals. The revisions add clinical nurse specialist to the list of personnel that can meet the requirements for staff immediately available to provide emergency care. The revisions also allow a registered nurse with training and experience in emergency care to conduct specific medical screening exams if the requested exam is within the registered nurse’s scope of practice. These changes are effective immediately.


MACRA

MHA Issue Brief

HHS Finalizes MACRA MIPS, APM and Criteria for Physician-Focused Payment Models

The U.S. Department of Health and Human Services announced the release of the final rule which finalizes the new payment system for Medicare clinicians.  The rule finalizes the Medicare merit-based incentive payment system, the alternative payment model incentive under the physician fee schedule and criteria for physician-focused payment models.  HHS Secretary Sylvia Burwell stated “today, we’re proud to put into action Congress’s bipartisan vision of a Medicare program that rewards clinicians for delivering quality care to their patients.  Designed with input from thousands of clinicians and patients across the country, the new Quality Payment Program will strengthen our health care system for patients, clinicians and the American taxpayer”.  CMS is providing many documents, video’s and webinars about the program, including:


Emergency Preparedness Final Rule

The audio recordingand transcript of the October 5 MLN Connects® Call on Emergency Preparedness Requirements is now available. This call discussed the new requirements in the final rule, as well as how to plan for both natural and man-made disasters, while coordinating with other emergency preparedness systems.


Section 1557 Compliance

Nondiscrimination Notices


Engaging Your Community: A Guide for Nonprofit Hospitals

As recommended by MHA’s Hospital Tax Exemption Work Group and Board of Trustees, MHA staff has completed a guide to assist nonprofit hospitals in maximizing the provision and promotion of charitable programs and services. The guide describes numerous activities that enhance a nonprofit hospital’s tax exempt status and provides guidance on creating a community benefit report to publicize investments in the community.

Working Overtime: What HR Professionals and Managers Need to Know About the Department of Labor’s New Overtime Regulations

The U.S. Department of Labor has published its much-anticipated final rule updating the Fair Labor Standards Act overtime regulations. According to the DOL, changes in the overtime regulations likely will lead to more than 4.2 million workers being reclassified as non-exempt and, therefore, eligible for overtime compensation. The DOL further estimates that the rule may directly affect more than 500,000 workers in the health care industry. This program will discuss the FLSA’s existing overtime exemptions, the changes imposed by the DOL’s new rule, and provide participants with multiple strategies for complying with the new rule. Click here for more information provided by Vincent D. Reese, Esq. with Mickes O'Toole, LLC.

MHA Quality Assurance/Performance Improvement Guide

The MHA Acute Care and Critical Access Quality Assurance/Performance Improvement Guide is designed to help key hospital leaders recognize and understand the major components of the QAPI initiative. The 58-page guide will support your organization’s quality improvement efforts. The QAPI Guide is primarily designed for professionals who are new to their current position, organization or level of responsibility.

MHA Survey Manual

The MHA Survey Manual: A Guide to the Licensing and Certification Survey Process has been created to help hospital leaders prepare for and understand the federal and state hospital survey process. The 176-page manual provides tips on how to prepare for surveys, interact with surveyors, write plans of correction and avoid or appeal adverse actions.

Nov. 19 MHA Survey Manual Webinar (Part 1) – Recording | Slides

Dec. 17 MHA Survey Manual Webinar (Part 2) – Recording | Slides

CMS Regulatory Provider Updates


MHA Self-Assessment Checklists

MHA has developed self-assessment checklists for

acute care hospitals and critical access hospitals that will aid them with their internal assessments of their compliance with state hospital licensure regulations, Medicare Conditions of Participation and the interpretative guidelines.

Medicare Conditions of Participation (CoPs)

Acute Care Hospitals

State Operations Manual

Appendix A (11/20/15)

Recent Survey and Certification Memos

  • 16-21-all, CMS is clarifying requirements for providing services to justice involved individuals.  (5/3/16)
  • 16-01-Hospital, updates the interpretive guidance in Appendix A for pharmaceutical and nursing services’ conditions of participation. The revisions bring the COP guidance in alignment with current accepted standards of professional practice and updates guidance for compounded sterile operations outside of the pharmacy for medication administration. (10/9/15)
  • Transmittal 141 Appendix A was revised on July 10 to include changes in the Interpretative Guidelines for 42 CFR 482.26 radiologic services and 42 CFR 482.53 nuclear medicine. (7/10/15)
  • Transmittal 137, includes revisions to State Operations Manual Appendices A, G, L and T related to Hospitals, Rural Health Clinics, Ambulatory Surgical Centers and Swing Beds in hospitals. Interpretive guidance found in Appendices A, G, L and T have been revised to reflect recent regulation changes and to make clarifications and updates to existing guidance. (4/1/15)
  • 15-12-Hospital, Public Release of Three Hospital Surveyor Worksheets. Quality Assessment and Performance Improvement, Infection Control, and Discharge Planning. The worksheets are used by State and Federal surveyors when assessing compliance with any of these three CoPs. (Issued 11/26/14)

Compliance Resources


Critical Access Hospitals

State Operations Manual Appendix W (10/16)

Recent Survey and Certification Memos

  • 16-21-all, CMS is clarifying requirements for providing services to justice involved individuals. (5/3/16)
  • 16-08-CAH, Critical Access Hospital Recertification Checklist for Evaluation of Compliance with the Location and Distance Requirements (2/12/16)
  • 15-45-CAH, Clarification of Critical Access Hospital Rural Status, Location and Distance Requirements (6/25/15)
  • Transmittal 138, includes substantial revisions to State Operations Manual Appendix W for Critical Access Hospitals (4/7/15)
  • 15-19-CAH, Revised State Operations Manual (SOM) Appendix W, Critical Access Hospitals (1/16/15)

Compliance Resources


Life Safety Codes

State Operations Manual Appendix I (2/14/14)

Recent Survey and Certification Memos

  • 16-35-LSC, updates Appendix I-Life Safety in the State Operations Manual. There are two updates noted in the letter. First, language previously included and erroneously omitted related to information gathering was reinstated. Second, exit interview guidance was updated to reflect appropriate communications during the exit interview process. The letter denotes the changes in red. The changes will not be updated simultaneously in the online manual. (8/19/16)

Ambulatory Surgical Centers

State Operations Manual Appendix L (4/1/15)

Home Health and Hospice

State Operations Manual Appendix M (10/9/15)

End-Stage Renal Disease Facilities

Updated State Operations Manual Appendix H (8/3/08)

Psychiatric Hospitals and Units

  • Psychiatric Unit Criteria Worksheet Form CMS-437 (4/06)
  • State Operations Manual Appendix AA (10/9/15)
  • State Operations Manual Appendix N for Psychiatric Residential Treatment Facilities (12/19/14)

Rehabilitation Hospitals and Units

  • Rehabilitation Hospital Criteria Worksheet (6/12)
  • Rehabilitation Unit Criteria Worksheet (6/12)

Outpatient Physical Therapy or Speech Pathology Services

State Operations Manual Appendix E (7/25 /14)

Swing Beds in Hospitals


Quality/Regulatory Orientation Guide

MHA's Quality/Regulatory Orientation Guide is primarily designed for professionals who are new to quality improvement or regulatory compliance or new to their organization. (12/1/15)

Required Orientation and Education Crosswalk for Acute Care Hospitals — Synopsis includes requirements from state and federal agencies, as well as the Joint Commission. (3/16)

Required Orientation and Education Crosswalk for CAHs — Synopsis includes requirements from state and federal agencies, as well as the Joint Commission. (3/1/14)

State and Federal Hospital Signage Requirements Resource Guide (1/3/17)

Hospital Training for Unlicensed Assistive Personnel toolkit includes tools and resources to assist hospitals in meeting the state training requirements for unlicensed assistive personnel in hospitals.

Safe Patient Handling toolkit includes the rule text, a brief overview and recommendations for compliance with the state safe patient handling rules.

The Tobacco-Free Hospitals resource guide for creating tobacco-free hospitals is designed to assist hospitals in meeting the hospital regulations banning tobacco use.

MHA Quality Assurance/Performance Improvement Guide

The MHA Acute Care and Critical Access Quality Assurance/Performance Improvement Guide is designed to help key hospital leaders recognize and understand the major components of the QAPI initiative. The 58-page guide will support your organization’s quality improvement efforts. The QAPI Guide is primarily designed for professionals who are new to their current position, organization or level of responsibility.

MHA Survey Manual

The MHA Survey Manual: A Guide to the Licensing and Certification Survey Process has been created to help hospital leaders prepare for and understand the federal and state hospital survey process. The 176-page manual provides tips on how to prepare for surveys, interact with surveyors, write plans of correction and avoid or appeal adverse actions. (2/16)

Nov. 19 MHA Survey Manual Webinar (Part 1) – Recording | Slides

Dec. 17 MHA Survey Manual Webinar (Part 2) – Recording | Slides

Missouri Hospital and Professional Licensure Rules

Hospitals Chapter 20 (7/31/14)

Rehabilitation Hospitals Chapter 22 (7/31/14)

Psychiatric Hospitals Chapter 24 (7/31/14)

Board of Pharmacy Statutes and Rules, Practice Guide