Cost Report Information: Tips to Ensure Acceptance
June 18, 2014 10:36 AM
Hospices that have recently completed a cost reporting year are in the throes of preparing their cost reports; these hospices will be using the current hospice cost reporting instructions. New cost reporting instructions could be issued at any time, though, and are anticipated to be applicable for cost reporting years beginning as early as October 1, 2014. The pending future cost report instructions will contain significant changes that will, eventually, impact all hospices.
NAHC’s Home Care & Hospice Financial Manager’s Association (HHFMA) has developed a uniform chart of accounts that coordinates with the forthcoming changes, and has undergone CMS review to ensure consistency. If hospices have not already done so, they are strongly encouraged to begin using the uniform chart of accounts now so they will have the correct data to submit for future cost reporting periods. When the pending cost report changes become applicable, CMS will also institute additional edits that will assist providers and help to ensure greater accuracy and consistency in cost reporting.
Approximately 10 percent of all home health agency (HHA) and hospice cost report filings are rejected and returned to providers for failing to meet one (or more) of the seven acceptability criteria mandated by CMS. If a cost report requires rejection, the entire cost report package is returned to the provider as though a cost report has never been filed. The following issues and tips are presented to help you ensure your cost report is properly filed and accepted without issue or to minimize impacts resulting from a cost report rejection.
Providers that have their cost reports rejected that were received on or after the due date also have the unfortunate circumstance of having their payments suspended immediately. Payments cannot be restored until a corrected cost report has been re-filed. The payment restoration process may take 3 to 5 business days after receipt of a re-filed cost report.
File the cost report early. A grace period is granted by CMS for cost reports filed early that must be rejected. The grace period is established by CMS and is equal to the number of days the cost report was received before the due date. Therefore, the earlier the cost report is received the longer a provider has to resolve any rejection issues before its payments are suspended. Please note that the grace period does not include an allocation of days for mailing to and from the provider.
Electronic filing requirements have been in place for more than two decades. However, many cost reports continue to be rejected for having electronically submitted electronic cost report (ECR) and Print Imagine (PI) encryption codes that do not match the codes that are printed on the certification page of the cost report (Worksheet S), have electronic files that cannot be read/copied, or have no electronic files submitted on the Diskette/CD.
After saving the files to a Diskette/CD, insert the Diskette/CD in another computer and attempt to copy the two electronic files to that computer, read the electronic files that were copied, and ensure both the ECR and PI encryption codes displayed match exactly the encryption codes printed on the Worksheet S. Taking these steps would eliminate close to half of all cost report rejections. Also, some MACs prefer submission of the cost report via CD or flash drive. The use of diskettes has proven to be unreliable, as they are more susceptible to damage, corruption or formatting issues, resulting in unreadable or missing files.
The administrator or an officer of the facility must sign the cost report and certify the accuracy of the cost report. Although some provider types now have the Form CMS 339 Questionnaire incorporated in their cost reporting form, home health agencies and hospice providers are still required to file a separate Form CMS 339. As with the cost report, the form must be signed by the administrator or officer of the facility.
Originals signatures are required; electronic signatures or photocopies (or facsimiles) are not permitted. Some MACs recommend the officer or administrator of the provider sign the certification page of the cost report (Worksheet S) that contains the ECR and PI encryption codes using blue ink. The Cost Report Questionnaire (CMS-339) certification page should also be signed in blue ink to clearly indicate that the signature is original.
The cost report submission includes an incorrect settlement summary. In many instances, if the HHA cost report is filed with an underpayment or overpayment on the settlement summary the provider payments have been incorrectly reported on Worksheet D and/or Worksheet D-1.
Unless the HHA is claiming cost reimbursable services (i.e., flu vaccine costs) on Worksheet D, Part II, Line 12 (or other rarely used Worksheet D, Part II lines such as 19, 22, 23, and 25.50) the settlement summary on Worksheet S should be $0 for both Part A and Part B. Small dollar amounts indicate rounding errors when reporting payments from the PS&R report. Larger amounts indicate that the PPS Payment amounts reported on Worksheet D, Part II likely contain posting errors or missing PPS Payment amounts. We recommend a review of the PPS payments posted on Worksheet D in these instances. Please note that if the cost report is submitted with an overpayment indicated on the settlement summary, the overpayment is subject to collection by Palmetto GBA. Once the cost report has been filed, the overpayment cannot be corrected until the cost report has been final settled via Notice of Program Reimbursement (NPR). Filing a second corrected cost report will not cease the overpayment collection process.