"Bed Hold" Reimbursement Update

IHCA previously issued an alert to members in late December regarding the Indiana Office of Medicaid Policy and Planning (“OMPP”) posting of BT 201061, which provides formal notice of the elimination of reimbursement for bed-hold days on nursing facilities effective as of February 1, 2011. For a copy of this bulletin, click here. This change willspecifically eliminate reimbursement for the following codes: 180 (leave days), 183 (for therapeutic purposes), and 185 (from nursing homes for hospitalizations).

Since OMPP’s announcement, IHCA has received many questions from members about the impact of this reimbursement change on bed-hold policies and billing/cost-report procedures.IHCA has been in communication with OMPP, the Indiana State Department of Health (“ISDH”) and the Division of Aging (“DA”) regarding these questions and has requested that theagencies, either individually or collectively, issue guidance to the long term care profession to clarify what is or is not required of comprehensive care facilities as a result of this reimbursement change.

Several IHCA members have asked whether comprehensive care facilities will be “required” to hold beds for Medicaid residents after elimination of Medicaid reimbursement for bed-hold days. Under the current law, and the law as it will exist on February 1, 2011 when Medicaid bed-hold reimbursement is eliminated, there is no requirement that facilities hold beds for Medicaid residents (unless, of course, Medicaid reimbursement is being paid or the individual resident is paying the facility in order to hold the bed).

Under ISDH regulations, however, each facility must have a policy and provide written information to residents regarding bed-holds that is consistent with the Medicaid State Plan. The language in the Medicaid State Plan regarding bed-holds for comprehensive care facilities states “Although it is not mandatory for facilities to reserve beds, Medicaid will reimburse” facilities that meet the occupancy criteria and for 15 or 30 day periods for hospital and therapeutic leaves, respectively. That language gives facilities a choice as to whether it wants to hold beds for Medicaid residents, and if the facility chose to do so then the facility’s policy on bed-hold had to take into account the Medicaid State Plan. At the time of this publication, it is unclear whether the ISDH will be amending its rule (410 IAC 16.2-3.1-12(25) and (27)) in light of the Medicaid reimbursement change. Even if ISDH does not amend its rule to reflect the lack of a bed-hold policy under Medicaid, each comprehensive care facility must still have a policy in place and provide information to residents regarding bed-holds.

Other questions that IHCA has received relate to the discharge and re-admission process with Medicaid residents who have been on hospital or therapeutic leave. When the bed-hold reimbursement rule was adopted in 2002, OMPP published BT200204 that walked through the bed-hold reimbursement rule, the occupancy calculation and impacts of the reimbursement change on the 450B process and claims and financial reporting processes. Since publication of that bulletin, OMPP further clarified discharge, re-admission andthe 450B processes in the Medicaid Provider Manual. At the time of this publication, IHCA is aware that OMPP is analyzing the impact of the reimbursement change on each of the above discharge, re-admissions and claims issues and has offered to assist OMPP in issuing guidance to the long term care profession to clarify these processes going forward.

IHCA recommends that each comprehensive care facility examine its bed-hold policy and be prepared to amend the policies in order to take into account the elimination of Medicaid reimbursement for bed-holds and the facility’s operational needs. Each comprehensive care facility must, by ISDH rule, maintain these policies and information.

IHCA will continue to research and work on this issue in the coming weeks and will issue additional guidance at the appropriate time. IHCA is hopeful that guidance will become available prior to the February 1, 2011 effective date of the reimbursement change.
Please contact Zach Cattell at zcattell@ihca.org or 317-616-9001 with questions, comments, examples or other information about the bed-hold reimbursement change.