Failing to heed the feds' request to button up "under arrangement" agreements with suppliers could leave providers facing a slew of unexpected bills from suppliers - or even more dire consequences. Here's a surefire way to protect your business interests, without paying hefty legal fees.
Big risk: If the Centers for Medicare & Medicaid Services becomes aware that a facility is not paying suppliers as it should, the agency could determine that the facility has violated its Medicare provider agreement.
CMS recently made good on its promise to offer more guidance on the subject with a Medlearn Matters article, "Skilled Nursing Facility Consolidated Billing Service Furnished Under an 'Arrangement' with an Outside Entity."
At the same time, the agency unveiled its long-promised "best practices" Web site, which offers seven sample agreements designed to help providers fulfill the requirement outlined in Change Request 3592, released in December.
The new CR, which replaces CR 3248, reminds SNFs of a longstanding requirement to enter into an agreement with outside suppliers that provide "bundled" services for residents whose nursing home stays are covered by Medicare Part A. Bundled services are those that must be funded with the daily consolidated billing rate that facilities accept for a resident's care.
To read the full Medlearn article, go to www.cms.hhs.gov/medlearn/matters.