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Administration redoubles its efforts to improve quality of post-acute care for Medicare beneficiaries

Today, the Centers for Medicare & Medicaid Services (CMS) announced two initiatives to improve the quality of post-acute care. First, the expansion and strengthening of the agency’s widely-used Five Star Quality Rating System for Nursing Homes will improve consumer information about individual nursing homes’ quality. Second, proposed new conditions of participation for home health agencies will modernize Medicare’s Home Health Agency Conditions of Participation to ensure safe delivery of quality care to home health patients.

“We are focused on using as many tools as are available to promote quality improvement and better outcomes for Medicare beneficiaries,” said Marilyn Tavenner, CMS administrator. “Whether it is the regulations that guide provider practices or the information we provide directly to consumers, our primary goal is improving outcomes.” 

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On December 30, 2013, the Internal Revenue Service (IRS) issued guidance explaining the circumstances in which it will not challenge partnership allocations to its partners under IRC Section 47, The Rehabilitation Credit. The IRS, within a recent revenue procedure (Rev. Proc. 2014-12, 2014-3 IRB) establishes the requirements of a “safe harbor,” meaning that if the provisions in the Rev. Proc. are followed, the IRS will not challenge the partnerships’ allocation of the IRC Section 47 Rehabilitation Tax Credits to the partnerships’ partners.

Under IRC Section 47, the owner of a qualified rehabilitated building is entitled to claim a tax credit of 10 percent of the qualified rehabilitation expenditures starting in the year in which the property is placed in service.  The amount of the credit increases to 20 percent of the qualified rehabilitation expenditures made with respect to a certified historic structure.   

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The issues around patient data security are many – the message simple; the need to constantly consider the electronic threats to your data has never been greater. Many of our clients have done their checking on a regular basis and find that there are periodic lapses in procedures or in installation of "patches". The bottom line is you need to make sure your IT integrity is always up to date. Call us if you need to get some help.

Federal agency monitoring EHR certification leaves door open to hackers by not requiring the use of strong passwords and other safety standards
Published Date: August 8, 2014
By Lisa Smith

Strong passwords are the first line of defense against computer hackers. But a government report warns that patients are at risk because the certification process for electronic health records (EHRs) doesn’t require the use of a strong password. 

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Final rule strengthens tie between payment and quality improvement

The final rule issued on August 4 by CMS adopts improvements in the quality of care that limit payment for hospital acquired conditions (HACs) and readmissions. The rule, which updates Medicare payment policies and rates for inpatient stays at general acute care and long-term care hospitals (LTCHs) for FY 2015, builds on the administration’s efforts for better hospital patient outcomes and slowing the long-term health care cost growth.  

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One of the most recent internet vulnerabilities is expected to be the largest ever to hit.  The bug, known as “Shell Shock”, enables hackers to exploit the Unix shell used by millions of web servers, ultimately allowing the hacker to take control of the device and steal information from it.  Potentially vulnerable devices range from iPhones to internet-connected thermostats.  The Marcum Financial Institutions Services Group is hoping that all of you have already heard about this, but if not please see the links below. 

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The potential issues and security in healthcare related businesses can't be overstated. This recent piece from medical group management Association highlights the issue. Marcum has extensive capabilities for assisting healthcare organizations with data security and making certain that data is HIPAA compliant. 

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“The Sunshine Act” is about to take effect beginning on September 30, 2014. This is a national program being implemented by the Center for Medicare & Medicaid Services (CMS) in order to be more transparent and responsible to the general public. CMS is mandated to publish reported data on September 30, 2014. The first Open Payments program cycle is a partial data collection period of five months (August 1 through December 31, 2013). Each Open Payments program cycle beyond 2013 will consist of a full 12 months of calendar-year data to be collected and reported to CMS.

The program allows physicians and teaching hospitals to register and review the financial data submitted by applicable manufacturers and group purchasing organizations to initiate disputes if necessary before the data is made public.   

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In June, 2014, the Board of Governors of the Federal Reserve System, The Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency issued FIL 30-2014, “Intercompany Tax Allocation Agreements.”  The regulation provides guidance on tax allocation policies in the instances where a Holding Company Structure exists.  As a reminder, compliance is required no later than October 31, 2014.  For further information or assistance, please contact Brenda DeCosta or David St. Yves of Marcum’s Financial Institutions Services Group. 

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It is becoming increasingly difficult to make financial statements when carriers are making modifications to the networks on an ongoing basis. This article highlights some of what is occurring nationwide. It becomes increasingly important to be able to do financial modeling rapidly and accurately on a "what if" basis. Many of the physicians who receive notifications from UnitedHealth will need to be changing their employee and physician makes if they have significant portions of their patient revenue from this carrier. We have already found some physician and physician group clients who have had to make short-term (less than six months) changes in their physician and physician extender employees based on gains and losses from the Affordable Care Act and related network changes.

Published Date: June 17, 2014
By: Rachael Zimlich  

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Cybersecurity:  Investing in your Firm’s Future

Recent cybersecurity breaches such as Target and Neiman Marcus have caused the U.S. government to start implementing security initiatives throughout all sectors to help defend against cyber-attacks. According to a 2012 global survey of securities exchanges, 89% identified cyber-crime as a potential systemic risk and 53% reported experiencing a cyber-attack in the previous year.* 

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