Proceed With Caution: Contracts Between Senior Communities And Placement Agencies May Not Violate The Anti-Kickback Statute

In This Issue:

- Background of the Arrangement

- The OIG’s Analysis: How the Senior Communities Reduced Their Risk

- What Providers Should Know

- Excerpt from Background of the Arrangement:

The Advisory Opinion was requested by a nonprofit corporation that owns several senior communities and two skilled nursing facilities (“SNFs”). In the senior communities, staff helped with daily living activities, administer medications, and provide skilled nursing services to residents. A small portion of residents receiving services paid for them through a state Medicaid waiver. Further, some staff from the corporation’s SNFs provided federally reimbursable speech, occupational, and physical therapy to community residents.

Please see full Publication below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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