Bed-Hold Reimbursement and Policy Update

The IHCA recently received feedback from the Office of Medicaid Policy and Planning ("OMPP"), the Division of Aging (the "Division"), and the Indiana State Department of Health ("ISDH") regarding the impacts of OMPP's decision to eliminate Medicaid reimbursement for bed-holds effective February 1, 2011. The following guidance, in Q & A format, is based on the collective responses of the above agencies.

Q: Are comprehensive care facilities required to hold beds for Medicaid residents or any other residents?

A: No, there is no requirement that a comprehensive care facility hold a bed for any resident. However, every facility must have a bed-hold policy and must give information to residents about what the facility's bed-hold policy allows.

Q: What must be included in a facility's bed-hold policy?

A: At a minimum, the policy must state that Medicaid does not pay for bed-holds and, if the facility offers an option for residents to personally pay for holding a bed, what the resident's options are in order to hold the bed and the facility's charge for holding a bed. The policy must also address readmission of a Medicaid resident to the first available semi-private bed if the Medicaid resident has exceeded the Medicaid allowable bed-hold period, if the resident requires nursing home level care and is eligible for Medicaid. Because the Medicaid allowable bed-hold period as of February 1, 2011 is zero, a Medicaid resident must be re-admitted in the manner described above. Facilities must inform all residents upon admission of the facility's bed-hold policy and all residents must be informed thirty (30) days in advance of any changes to rates or services that are covered by the rates.

Q: Is a comprehensive care facility required to readmit a Medicaid resident that has left the facility on hospital or therapeutic leave?

A: Yes. Under Federal and State regulation, a comprehensive care facility must readmit a Medicaid resident to the first available semiprivate bed, assuming the resident requires comprehensive care services and qualifies for Medicaid, when the resident's leave exceeds the Medicaid coverage limitation. Because the Medicaid allowable bed-hold period as of February 1, 2011 is zero, a resident must be readmitted in the manner described above.

Q: How can a comprehensive care facility charge a Medicaid resident to hold a bed?

A: Because Medicaid will no longer reimburse to hold a bed under any circumstances, all bed-holds are considered a non-covered service that a resident may elect to personally pay for, if the facility offers such an option. In addition to the required information about the facility's bed-hold policy that must be given to a resident, the facility must follow the requirements for billing Medicaid recipients for non-covered services as set forth in the Indiana Health Coverage Programs Provider Manual, Chapter 4, Section 5. Facilities can only charge Medicaid residents for items and services requested by the resident.

Q: Will comprehensive care facilities be required to submit a new from 450B and resubmit pre-admissions screening forms following a hospital or therapeutic leave of absence?

A: A facility must resubmit a new form 450B and resubmit pre-admissions screening forms only when the resident has been discharged from the facility. Depending on the facility's bed-hold policy, a resident may not be discharged upon leave. In any event, as long as the resident intends to return to the facility there is no requirement to discharge the resident. If, however, the facility does not anticipate the residents' return to the facility the resident must be discharged and all new admissions criteria must be followed if the resident is re-admitted to the facility.

Q: Under what circumstances should a comprehensive care facility submit a claim to OMPP for bed-hold days?

A: Until January 31, 2011, comprehensive care facilities must submit claims for bed-hold days as set forth in the Indiana Health Coverage Programs Provider Manual Chapter 14, Section 3. Beginning February 1, 2011, comprehensive care facilities should not submit any claims for bed-hold days under any circumstances, including Revenue Code 180. Because OMPP will no longer reimburse for bed-hold days, OMPP will no longer be tracking bed-hold days via claims.

The OMPP is also providing further clarification on this issue on it's website.

The IHCA continues to collect questions about the impacts of the OMPP decision to eliminate Medicaid reimbursement for bed-holds. The IHCA is currently in discussion with OMPP and the Division regarding how the elimination of bed-hold reimbursement will impact the overall Medicaid rate setting process. Please contact Zach Cattell at zcattell@ihca.org or 317-616-9001 with any questions or comments.