Date: April 21, 2021
This notice is to remind long term care
providers that all forms and applications submitted on behalf of a resident
need to be correct and complete. As enrolled Medicaid providers, long term care
facilities must submit Medicaid applications, the 3654 form (Additional
Financial Information for Long Term Care Applicants) and all MEDI TAN submissions
with accurate information.
Providers need to exercise due diligence to
obtain the requested data and ensure its accuracy prior to applying for
Medicaid on behalf of a resident. Since three months backdating is available
when submitting a Medicaid application, providers have additional time to
collect the information needed for completion.
When completing an application or the 3654 form:
- The family, POA
(Power of Attorney), guardian and resident should be consulted in order to
collect the most accurate information and determine when a question should
be marked yes, no or left blank for unknown.
- Answering a
question “no” and leaving an answer blank because the information is
unknown are different responses.
- A response should
only be marked “no” if it is determined that the answer is actually “no”
to one of the questions. For example, the provider determined that a
client does not have a bank account.
- If the answer is
unknown, then the response should be left blank as unknown. For example, you are not able to
determine if a client has a bank account.
All information submitted on behalf of a
resident by a provider must be correct and complete.
The following list contains
examples of forms and applications which are not considered complete and/or
correct:
- Submitting Medicaid applications with incorrect
information.
- Selecting “no” to questions on an application
without making an effort to obtain the data prior to submission.
- Submitting TANs with incorrect screening
information.
- Falsifying TAN information on an admission
record.
o
Data fields cannot be edited after submission
in MEDI (TAN digits, Screening Info, Provider Name and Number)
o
Updating TAN data fields require a new TAN
submission.
- Selecting that an applicant is private pay when
they are not.
- Failing to report the death or discharge of a
recipient.
- Failing to identify a spouse when they are
known or reasonably should be known.
When
submitting an application on behalf of a resident, providers and staff should
be mindful of the following attestation in ABE.
Long term care providers, like all enrolled
providers, are expected to act in accordance with all laws, regulations,
provider handbooks, guidance, their provider enrollment agreement, and other
applicable provisions. Failure to do so may subject the provider to referral to
the HFS OIG or other authorities for sanction or further actions.
Please review the below resources for more
information on provider expectations.
- OIG Code of Conduct for Nursing Home Providers
o
https://oig.hhs.gov/authorities/docs/cpgnf.pdf
- CMS Nursing Home Provider Booklet
o
https://www.cms.gov/Medicare-Medicaid-Coordination/Fraud-Prevention/Medicaid-Integrity-Education/Downloads/nursinghome-provider-booklet.pdf
Questions regarding this
bulletin may be directed to the Bureau of Long Term Care at
1-844-528-8444.
Kelly Cunningham, Administrator
Division of Medical Programs
