Reminder to providers: CMS modified supporting documentation requirements for cost-reporting periods beginning on or after October 1, 2018

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On August 17, 2018, the Centers for Medicare and Medicaid Services (CMS) issued the FY 2019 Medicare IPPS final rule. Part of the rule modified the supporting documentation required under 42 CFR 413.20 to be submitted with provider cost reports. The new requirements are applicable for cost reports submitted for cost-reporting periods beginning on or after October 1, 2018. Those cost reporting periods are beginning to close, and providers are starting to prepare cost reports pursuant to these new requirements.

The required documentation is different for several types of cost report elements, including:

  • Teaching hospitals must include the Intern and Resident System Data.

  • Hospitals claiming Medicare bad debt reimbursement must include a detailed bad debt listing matching the claimed amount of bad debt in the cost report.

  • Disproportionate Share Hospitals (DSH) must submit a detailed listing of the Medicaid-eligible days matching the claimed Medicaid-eligible days in the cost report. They also must update this listing if the cost report is amended.

  • DSH facilities reporting charity care and/or uninsured discounts must submit a detailed listing of these discounts that corresponds to the amounts claimed in the cost report. This information must include patient name, dates of service, insurer and amount of charity given to the patient.

  • Providers claiming home-office cost allocation must ensure that a statement of these costs tying the home-office cost report and the provider’s claimed amount must be submitted to the provider’s servicing contractor. The requirements for these submissions are slightly different depending on whether the home-office cost report is filed in the same year period as the provider’s cost report.

Providers need to be aware of the cost-report documentation requirements, as cost-report submissions made without the required documentation will be rejected by the Medicare Administrative Contractors (MACs) under 42 CFR 413.24(f)(5)(i).

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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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