This week, the California Department of Public Health (CDPH) released its 2018 Fee Report, which proposes to increase hospital fees by 5 percent (from $515.04 to $540.79 per licensed bed) and add a supplemental facility fee of $50.53 per bed for hospitals in Los Angeles County.
Historically, the department has contracted with Los Angeles County to use county employees, rather than state workers, to perform facility licensing and certification duties for facilities in that area. The budget proposal asserts that the cost of doing business is higher there than in other parts of the state, and that licensing fees are commensurate with Los Angeles County’s costs to complete the workload. This increase coincides with a proposal to extend the current Los Angeles County contract for one year, and then negotiate a three-year contract beginning in July 2019. The proposal includes a “pay-for-performance” program.
CHA is analyzing the proposal, but generally supports using performance metrics for improvement across the entire state, rather than in only one jurisdiction.
The California Department of Public Health has released the attached All Facilities Letter 18-11, clarifying a new law that increases — from a maximum of $20,000 to a maximum of $75,000 — the fine for a health facility that discriminates or retaliates against a patient, employee or other health care worker for presenting a complaint against or cooperating in an investigation of the facility. This letter supersedes All Facilities Letter 17-28 and clarifies that the new law does not apply to long-term health care facilities.
The California Department of Public Health has released the attached All Facilities Letter 18-07, informing health care facilities that Assembly Bill 1456 (Chapter 151, Statutes of 2017) extends the maximum duration of waivers issued to unlicensed psychologists gaining qualifying experience toward their license from three to four years. The law, which took effect July 31, 2017, makes no changes to waiver eligibility requirements. Questions about requesting a waiver should be directed to the department’s State Facilities Section at (855) 804-4205 or firstname.lastname@example.org.
Following the Ebola epidemic in 2014, the Centers for Disease Control and Prevention established the National Ebola Training and Education Center to help health care and public health professionals better deliver safe and effective care to Ebola patients. To that end, the Center will offer a series of workshops in 2018. While there are no tuition costs for the programs, space is limited.
Each two-day workshop is comprised of faculty from the health care institutions with experience treating patients with Ebola – Emory University, the University of Nebraska Medical Center/Nebraska Medicine and the New York City Health + Hospitals/Bellevue. The first workshop will be held Jan. 30-31, 2018 in Atlanta; the second will be in Omaha on March 27-28, 2018. Details about the workshops, including registration and educational credit information, are available in the attached flyer.
The Medical Board of California has released guidelines for providers recommending cannabis for medical purposes. The guidelines emphasize the importance of collaboration between physicians and their patients, noting that — prior to authorizing or recommending cannabis — physicians should document an established physician-patient relationship with mutual understanding of shared responsibility for the patient’s care. The board also recommends that physicians document a medical examination of the patient, including the patient’s history of present illness, social history, past medical and surgical history, alcohol and substance use history, and diagnosis requiring the cannabis recommendation.
Importantly, the guidance notes that Business & Professions Code Section 2525.3 states that recommending cannabis to a patient without appropriate examination and medical indication constitutes misconduct. The guidance goes on to detail treatment agreements, outlines qualifying conditions, and provides information on monitoring and adapting the treatment plan. The board’s guidance is not intended to mandate the standard of care.
A new program supported by the California HealthCare Foundation and led by Zuckerberg San Francisco General Hospital aims to help hospitals start medication-assisted treatment services for opioid use disorder. The program, called Project SHOUT (Support for Hospital Opioid Use Treatment), offers free resources for clinicians to use in starting or maintaining patients on buprenorphine and methadone. In addition to evidence-based guidelines, toolkits, expert coaching and grand-rounds presentations, the program will offer a weekly webinar series beginning Nov. 15. For more information, see the attached flyer or email email@example.com. To receive program updates, register online.
The California Department of Public Health (CDPH) has released the attached All Facilities Letter with new guidance for submitting plans of correction. Earlier this year, the Centers for Medicare & Medicaid Services (CMS) expanded the ways in which providers may submit plans. While previously required to submit plans of correction written on on the right side of CMS Form 2567, providers now have the option of instead including their plan as a separate attachment. CDPH has extended this practice to state-issued 2567 forms. More details are available in the attached letter.
The California Department of Public Health has issued the attached All Facilities Letter stating that health facilities affected by recent California wildfires — including those in Butte, Lake, Napa, Orange, Mendocino, Nevada, Sonoma, Yuba and Solano counties — are eligible to apply for waivers of certain licensing requirements. The waivers are intended to expedite recovery efforts and ensure that hospitals and other health facilities remain open. Details on obtaining a waiver are included in the attached letter; requests should be submitted to firstname.lastname@example.org.
A recent All Facilities Letter (AFL 17-20) from the California Department of Public Health (CDPH) states that, as of Oct. 1, home health agencies may expedite the licensing process by hiring a Centers for Medicare & Medicaid Services approved accreditation organization to conduct the initial state licensing survey, avoiding the current delay of three months to two years in initial application survey completion. If a home health agency chooses to hire its own accreditation organization and passes its initial survey, the CDPH Centralized Applications Unit will issue a six-month provisional license. More details on the process, as well as a list of approved accrediting organizations, are available in the attached AFL.
Under AB 2325 (Chapter 354, Statutes of 2016), pathologists will be required to electronically report cancer diagnoses to the California Cancer Registry (CCR) beginning Jan. 1, 2019. To help providers meet this requirement, the CCR has released an implementation guide defining reporting requirements as well as a standardized format for reporting. Pathologists and pathology software providers will need to review the guide and register through the CCR online portal to meet reporting requirements. More information is available at www.ccrcal.org/AB2325.shtml.
The California Department of Public Health has released the attached All Facilities Letter (AFL 17-17) notifying providers that its San Francisco District Office is transferring oversight of certain facilities in Santa Clara County to the San Jose District Office. Effective Oct. 1, all facilities listed in the AFL should report complaint and entity-reported incidents to the San Jose office.
The California Department of Public Health (CDPH) requests stakeholder input in revising regulations related to general acute care hospital clinical laboratory service. In the attached All Facilities Letter (AFL 17-18), CDPH outlines the specific areas in which it is requesting feedback, including anticipated costs imposed by requiring certain approvals in writing, whether hospitals have differing lab procedures for inpatients versus outpatients and who determines whether a pathologist candidate’s qualifications are equivalent to those required for certification. Responses are due Sept. 29 and may be submitted either online or via email; more details are included in the AFL.
The Centers for Medicare & Medicaid Services has released its annual report to Congress on Medicare’s review, validation and oversight of approved accrediting organizations (AOs). The report identifies nine approved Medicare AOs, as well as seven approved under the Clinical Laboratory Improvement Amendments of 1988 (CLIA), and outlines their actions during fiscal year 2015 as compared to previous years. The report also analyzes CLIA Validation Program results.
The California Department of Public Health (CDPH) has released its fiscal year 2017-18 health care facility license fee schedule. As outlined in the attached All Facilities Letter, renewal notices and applications will be sent to facilities’ licensees 45-120 days prior to license expiration. To complete the license renewal, licensees should validate the number of beds listed on the renewal fee page; print applicable health care facility license numbers on the front of the payment; include the bottom portion of the renewal notice fee page with the payment; and mail the application portion of the notice as indicated on the last page of the application. License fee questions should be directed to RCollection@cdph.ca.gov.
The Centers for Medicare & Medicaid Services (CMS) has issued a memo to providers addressing infection control for end stage renal disease (ESRD) facilities and testing for hepatitis C. Under the CMS requirements, facilities must demonstrate that they follow standard infection control procedures including routine serological testing and immunization, surveillance, training and education. However, providers should note that hepatitis C screening is not required by these guidelines, and that surveyors should not cite these facilities for failure to conduct routine or periodic screening. Questions should be directed to ESRDQuestions@cms.hhs.gov.
The Centers for Medicare & Medicaid Services (CMS) has issued a Survey and Certification memo updating requirements for plans of correction and allegations of compliance. Effective immediately, providers/suppliers and clinical laboratory improvement amendments (CLIA) laboratories are no longer required to write their plan of correction on the right side of CMS Form 2567; for CLIA, this also applies to allegations of compliance. Instead, the plan for correction or allegation of compliance may be submitted as a separate document, attached to the form. However, the laboratory director or provider/supplier representative’s signature is still required on the first page of CMS Form 2567. Providers may continue to document the plan of correction on the right side of the form if they choose. Questions about the memo should be directed to providers’ regional office.
Effective January 2017, hospitals that perform sterile compounding must meet new regulatory requirements from the California State Board of Pharmacy. Beyond updating processes and procedures, hospitals will be required to improve or reconfigure facilities for ventilation, install new equipment for sterility and ensure employee protections.
The California Department of Public Health Center for Health Care Quality has released quarterly performance metrics on long-term care facilities and — for the first time — non-long-term care facilities, including general acute hospitals. The reports provide data through Sept. 30, 2016, on facility complaints, entity-reported incidents and relicensure surveys.
The Centers for Medicare & Medicaid Services (CMS) has posted frequently asked questions about the Medicare Outpatient Observation Notice (MOON), which went into effect March 8. The FAQs provide more information about how to complete the MOON’s “free text field,” which is intended to address the reason patients are in outpatient observation care rather than inpatient care. The FAQs also address alternate languages, modifying the form, and whether the form should be provided to Medicare Advantage enrollees.
As a reminder, CMS requires hospitals, acute psychiatric hospitals and critical access hospitals to provide all Medicare-eligible patients who receive outpatient observation services for more than 24 hours with a written MOON and oral notification. In addition, as of Jan. 1, state law requires hospitals to provide a written notice to a patient on observation status who is cared for in a hospital’s inpatient unit or in an observation unit, or following a change in a patient’s status from inpatient to observation. The notification must be provided as soon as practicable. A CHA webinar on the notification requirements of state and federal law is available at www.calhospital.org/observation-services-webinar-recording.
As of Jan. 1, SB 1076 requires hospitals to provide a written notice to certain patients receiving observation services. Beginning March 8, CMS will require hospitals to provide the Medicare Outpatient Observation Notice (MOON) and verbal notification to Medicare beneficiaries receiving outpatient observation services.