decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
HHA Model Compliance Plan / Services to patients who reside in assisted living facilities
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Article Overview
This article explains how home health agencies should evaluate whether services furnished to residents of assisted living facilities are appropriate for reimbursement and how to reduce the risk of submitting unallowable claims. It is aimed at HHAs, compliance staff, and billing professionals who need to understand overlap between home health services and services the facility is required to provide under state licensure or contract. The discussion also highlights related compliance concerns raised by audits and investigations, including referral and anti-kickback risk, and emphasizes coordination with state licensing authorities when facility care obligations may not be met.
Why This Topic Matters
Claims for services that duplicate facility-provided or facility-required care may be unallowable, creating payment, audit, and compliance exposure for home health agencies. The article helps organizations assess resident eligibility, document facility obligations, and align internal review processes with OIG expectations.
What You Will Learn
- How home health agencies can assess services provided to residents of assisted living-type facilities for reimbursement compliance.
- Why state licensure and resident-facility service agreements matter in evaluating whether services duplicate facility obligations.
- What general compliance steps are recommended to reduce the risk of improper claims and related referral concerns.
- When concerns about a facility’s failure to provide required care may warrant contacting the appropriate state licensing authority.
Who Should Read This
- Home health agencies
- Compliance officers
- Billing and coding staff
- Healthcare auditors
- Medicare providers
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