OIG advisory opinion released

Categories: Policy.

The OIG Advisory Opinion (PDF) involves a “demonstration program” to test a fully integrated care system that manages the continuum of benefits for dually eligible beneficiaries.

The State (redacted) has selected several managed care organizations to provide services to dually eligible beneficiaries in the Demonstration, and at least one of the MCOs is paying the nursing facility directly for room and board, and in an amount less than 100% of what the nursing home would have gotten from the MCO if the patient hadn’t elected hospice. The hospice is asking the OIG whether it can provide a supplemental payment to the nursing facility, up to the amount the nursing facility would have gotten from the MCO if the patient wasn’t in hospice. 

Upon analysis, the OIG determines that this is OK because it’s very similar to the scenario on which they’ve previously opined, finding it was OK for a hospice to pay nursing facilities up to 100% of the Medicaid room and board rate rather than the 95% that the Medicaid program pays the hospice.

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