By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law
For Assisted Living Facilities (ALFs) in Florida, it’s time to do a little brushing up on your compliance material.
Beginning in January 2015, the Agency for Health Care Administration (AHCA), Office of Inspector General (OIG), Bureau of Medicaid Program Integrity (MPI), will conduct site visits to determine compliance with the Florida Medicaid Provider General Handbook and the Assistive Care Services Coverage and Limitations Handbook. This is just one of several initiatives aimed at ALFs to curtail fraud, waste, and abuse in the Florida Medicaid program.
Be Prepared.
The goal of a site visit is to determine if providers are rendering and documenting required services; to determine if assistive care services are being rendered by qualified and properly trained staff; to identify quality of care/environmental issues; and, to document and report ALF providers’ deficiencies to any managed care organizations with which the ALF is contracted.
According to the Florida Assisted Living Association (FALA), the majority of MPI sanctions concerning these fines are associated with the failure to have the following completed forms on file for each resident:
1. AHCA Form 1823 – The Health Assessment
2. AHCA Form 035 – The Certification of Medical Necessity
3. AHCA Form 036 – Medicaid Service Plan
Knowing is Half the Battle.
This announcement shows that the government will continue rigorous and thorough enforcement efforts this year. ALFs should consider this a fair warning to get supporting documentation in order. If you’re worried your ALF may not be in compliance, we suggest getting a compliance assessment. If your ALF is being audited we always suggest contacting an experienced health law attorney immediately. For general tips on how to respond to a Medicaid audit, click here for a previous blog.
Comments?
Did you know about these anti-fraud initiatives? Do you feel like your ALF is prepared for a site visit? Please leave any thoughtful comments below.
Contact Health Law Attorneys Experienced in Representing Assisted Living Facilities.
The Health Law Firm and its attorneys represent assisted living facilities (ALFs) and ALF employees in a number of different matters including incorporation, preparing contracts, defending the facility against malpractice claims, licensing and regulatory matters, administrative hearings, and routine legal advice.
To contact The Health Law Firm, please call (407) 331-6620 or (850) 439-1001 and visit our website at www.TheHealthLawFirm.com.
About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law. He is the President and Managing Partner of The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida, area. www.TheHealthLawFirm.com The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone: (407) 331-6620.
The Health Law Firm” is a registered fictitious business name of George F. Indest III, P.A. – The Health Law Firm, a Florida professional service corporation, since 1999.
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