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Comfortable comfort in compliance

Nancy J. Beckley ( is President of Nancy Beckley & Associates LLC, a rehab compliance consulting firm in Milwaukee, WI.

This year may be best described as “the year of living dangerously,” as we get ready to end the summer and look forward to a Labor Day weekend that signals the march to the end of the year. The disruption caused by the new skilled nursing facilities’ Patient-Driven Payment Model and the new home health Patient-Driven Grouping Model gave way to COVID-19 and helped declare a pandemic and a public health emergency.

Over the past year and a half, the Centers for Medicare & Medicaid Services (CMS) has updated the Emergency Preparedness interpretive.[1] It started in February 2019[2] and continued in September 2019,[3] when a collective sigh of relief was heard by all providers related to the effects of burden reduction. No sooner had policies and procedures been updated than the CMS Center for Clinical Standards and Quality and the Quality, Safety & Oversight Group began releasing memos related to COVID-19, emergency preparedness, and infection control.

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