Hospices are no stranger to federal surveys but will need to become familiar with the new survey process and enforcement remedies, which will become effective January 1, 2022. These changes will greatly expand the federal government’s authority to impose sanctions on hospices. Whereas in the past, hospices implemented plans of correction in response to deficiencies identified during federal surveys, they are now also facing civil monetary penalties, suspension of payment for new admissions, temporary management, directed plan of correction and directed in-service training. In this webinar, Wiggin and Dana attorney, Jody Erdfarb, will explain the rules regarding how these federal sanctions work and how hospices can fight back through the appeal processes. In this new climate, it is essential for hospice agencies to understand their rights and the avenues available to defend themselves.

Program Objectives (At the completion of this session, participants will be able to….)

• Provide an overview of the revised CMS hospice survey and enforcement regulations, including an explanation of civil monetary penalties and the suspension of payment for new admissions.
• Describe the administrative appeal process with an Administrative Law Judge and Departmental Appeals Board, and the judicial review process in court.
• Offer tips on what you can do during your survey to give you the best chance at success in challenging any deficiencies.