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On December 23, 2020, the OIG published Advisory Opinion 20-06, concluding that it would not impose penalties or sanctions under either the beneficiary inducement prohibitions of the civil monetary penalty statute (CMP) or the Anti-Kickback Statute(AKS) related to a management company providing Medicaid enrollment application assistance services to patients of skilled nursing facilities (SNFs) and home health agencies (HHAs) affiliated with the management company.
Overview of the Facts
The Requestors are a management company that provides financial, marketing and administrative services to SNFs and HHAs, and two SNFs and an HHA that are affiliated with the management company. Under the proposed arrangement, the affiliated SNFs and HHA would refer individuals they believe are eligible for Medicaid to the management company for Medicaid enrollment application assistance (Services). The individuals referred would be current patients or, rarely, individuals who have already selected the affiliated entity, but are not yet patients. The management company would provide assistance completing the application, compiling documentation, meeting deadlines and complying with applicable requirements. These Services would not include the provision of any health care items or services.