Slow and Steady

Ah—springtime in Iowa.

One of my favorite smells is the scent of a freshly cultivated field. 

(In other words, I love the smell of new dirt in the spring.)

To get that fresh‑dirt smell, the tractors must move from field to field using the roads.

Moving s-l-o-w-l-y.

Often with a line of cars patiently (or not-so-patiently) waiting to pass.

On a two‑lane highway.

With a double‑yellow line and very short passing zones.

If you know, you know.

...

That slow, steady pace is exactly what came to mind as I reached the final section of risk in the OIG’s Nursing Facility ICPG: Other Risk Areas — or more simply: 

How does your facility work with outsiders?

• Related‑Party Transactions

• Physician Self‑Referral (Stark Law)

• Anti‑Supplementation

• HIPAA Privacy, Security, and Breach Notification

• Civil Rights

For many nursing facility administrators, these topics sit outside their day‑to‑day comfort zone. 

They’re not flashy. 

They’re not urgent. 

But they matter — and they require the same slow, methodical approach as following a tractor down Highway 163.

Because if you rush, you miss things. And in compliance, missing things has consequences.

A few questions to consider:

• Do you have a reliable method for tracking and reporting related‑party transactions?

• Are the goods and services you purchase truly at fair market value?

• When using an outside lab or therapy group, are Stark Law requirements part of your process — or an afterthought?

• Are residents ever charged for what Medicare or Medicaid does not cover?

These aren’t “gotcha” questions. They’re the double‑yellow lines meant to keep you safe.

What’s the biggest challenge you face in this area — the one that makes you slow down like you’re stuck behind a tractor in April?

(Image created with AI Assistance.)