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.