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Filing Requirements for a Provider for Cost Report Appeal
Provider requests for a cost report appeal must be directed and submitted to the appropriate party based on an estimated reimbursement materiality threshold in dispute as outlined below:
CMS Issues a Final Rule on PRRB Appeals
On May 23, 2008, the Centers for Medicare and Medicaid Services published a final rule that substantially changed the procedures for appealing a Medicare cost report determination included in a notice of program reimbursement (NPR) before the PRRB. Many of the revised changes will require providers to improve preparation and filing requirements before and after filing Board appeals.
Because of the changes in the final rule, providers will need to implement a number of new and updated processes in order to respond to appeal filing requirements. Providers must identify, document and file all disputed audit issues within the final rule’s stringent guidelines. The final rule was effective August 21, 2008, with a few exceptions.
Provider Reimbursement Review Broad Rules are Revised
CMS has posted the new PRRB rules on its website. The new PRRB rules will apply to appeals pending as of August 21, 2008, or filed on or after that date and will supersede the PRRB instructions which were in effect as of March 1, 2002.
The new PRRB rules coincide with CMS’s final rule, which was published in the Federal Register on May 23, 2008.
Revised Initial Appeal Filing Procedures
The CMS final rule (dated May 23, 2008) and the PRRB rules (effective August 21, 2008) outline a significant number of changes to the PRRB appeal process which will restrict a number of filing options and documentation requirements for providers wishing to file PRRB appeals.
Perhaps the most significant and costly change for providers in the final rule is that there now is a time limitation on adding issues before the Board. Under prior PRRB rules, a provider could add issues anytime before the hearing date, which under most circumstances would be several years from the original filing date.
Under the new PRRB rules, appeal issues may only be added to an appeal for a period of up to 240 days after the issuance of the Notice of Program Reimbursement (NPR). The latter 240 days amount is the result of limiting the time period for adding issues to no later than 60 days after the expiration of the applicable 180 days filing deadline.
Due to the new PRRB rules, providers should make every effort to file all disputed issues in their initial appeal request for hearing. Additionally, providers should systematically identify, document and finalize all disputed issues as early as possible before and after the fiscal intermediary audit of subject cost report.
Our Services Include the Following:
Review all open Medicare cost reports in order to identify, analyze and document material appeal issues. An example of potential audit issues include the following: - SSI % days - Medicaid eligibility days - FTE count - GME program review
HCS provides services in all facets of PRRB appeal process, which includes but not limited to the following service items:
Next Service:
Medicare Bad Debt Compilation and Systematic
Reviews
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Providers must file their written request for
cost report appeal within 180 days of the date
of the applicable Notice of Program
Reimbursement (NPR) or the final determination
letter related to an exception/exemption
request.
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