Nursing Facility Reimbursement Appeals Reduction Plan

In 2011, the Indiana General Assembly passed legislation requiring the Office of Medicaid Policy and Planning (OMPP) to utilize portions of the increased Quality Assessment Fee (QAF) collected from nursing facilities to discharge provider liability for certain pending administrative appeal(s). 
Last week, IHCA met with OMPP officials to review draft documents concerning the process for executing this requirement.  OMPP has called the project the Appeals Reduction Plan.

The OMPP Office of General Counsel (OGC) presented draft documents concerning the process for withdrawal of audit and rate appeals filed for Rate Effective Dates on or before 7/1/11.  In exchange for the withdrawal of the filed appeals, the provider’s potential liability from the audit adjustment will be discharged as the State will utilize the $20M in QAF to satisfy that potential liability.  Obviously a provider’s decision to withdraw the appeal will be an individual choice based upon many factors.  IHCA’s Payment and Reimbursement Committee has been very active in discussing this issue and is providing guidance to IHCA members.

The Appeals Reduction Plan is likely to begin with a small number of providers in about 4 to 6 weeks, once the draft documents are finalized.  IHCA will have another opportunity to review the documents prior to the program’s start.  OMPP is likely to meet with the first small group of providers and their counsel (at the provider’s choice) to walk through the process and iron out any issues before rolling the program out statewide.  OMPP anticipates, in coordination with Myers & Stauffer, that the batch process will work backwards in time with the newest appeals being dealt with first, followed by older appeals.

IHCA staff will continue to work with the State and update IHCA members on the issue as new information becomes available.  Please contact Zach Cattell at 317-616-9001 or zcattell@ihca.org with any questions.