JK Audit & Reimbursement Update - HFMA Central New York ... · •FY 2014 SSI NPR’s due by May 31, 2018 (only applies to desk reviews not audits) 90% NPR’d or sent for processing

JK Audit & Reimbursement Update

March 2018

Proprietary and Confidential

Disclaimer

National Government Services, Inc. has produced this material as an informational reference for providers furnishing services in our contract jurisdiction. National Government Services employees, agents, and staff make no representation, warranty, or guarantee that this compilation of Medicare information is error-free and will bear no responsibility or liability for the results or consequences of the use of this material. Although every reasonable effort has been made to assure the accuracy of the information within these pages at the time of publication, the Medicare Program is constantly changing, and it is the responsibility of each provider to remain abreast of the Medicare Program requirements. Any regulations, policies and/or guidelines cited in this publication are subject to change without further notice. Current Medicare regulations can be found on the Centers for Medicare & Medicaid Services (CMS) Web site at http://www.cms.gov.

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http://www.cms.gov/


No Recording

• Attendees/providers are never permitted to

record (tape record or any other method) our

educational events

– This applies to our Webinars, teleconferences, live

events, and any other type of National Government

Services educational event

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Website Survey!


Agenda

• Recent CMS Updates

• JK Workload Status& Miscellaneous Items

• 2019 Wage Index

• Cost Report Filing

• Interim Rate Reviews

• MCReF - Medicare Cost Report E-Filing System

• Reopenings

• Provider Based Requests

• Questions

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Recent CMS Updates


Recent CMS Updates

Provisions with extensions by legislature:

1. Low Volume Hospital Adjustment

2. Medicare Dependent Hospital• Awaiting CMS direction

• Watch for news articles on our website for instructions via www.ngsmedicare.com

2018 MAC Satisfaction Indicator (MSI) Survey• Link on our website to an external vendor (CFI Group) conducting the

survey

• Measures your satisfaction with our processes and service delivery so we can gain valuable insights and determine process improvements

• News article on our website dated 3/5/2018 with the improvements implemented based on 2017 MSI feedback

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Jurisdiction K Audit Workload and Miscellaneous Items


JK Audit Workplan

Option Year 5 began on 03/01/2018 and will run through 02/28/2019

• Approximate JK inventory (NY, CT, ME, MA, NH, VT, RI)

• 430 Hospitals

• 2,600 Other than hospitals (i.e. freestanding: SNF, HHA, ESRD, CORF, Home Office, etc.)

• Medicare cost report audit Workload

• Desk reviews (Currently reviewing FYE 2015 cost reports primarily)

• Audits (72 total Audits)

• HITECH Audits (18 in total - subcontracted to Kujawa & Batteau)

• Final Settlements (including cases put on hold: FY 14 SSI, outlier reconciliation, etc.)

• Reopenings (main focus on RAC PIP)

• Appeals

• Medicare Secondary Payer audits (subcontracted to Systematic Billing)

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SSI Update

• FY 2014 SSI

NPR’s due by May 31, 2018 (only applies to desk reviews not audits)

90% NPR’d or sent for processing

135 NY providers (84 NPR’d, 27 with NPR Hub for processing, 5 outlier referrals that

may not settle by May, 14 Allina/NY backlog jobs that wont settle by May, remaining 5

are in process)

By June 30th any FFY 2014 SSI hospital that hasn’t been referred to audit should be

NPR’d unless it is being held for one of the reasons above

• FY 2015 SSI

Published July 2017 by CMS

Held NPRs through wage index season to allow for any wage adjustments to be included

in final package (similar approach as last year)

This also allowed any amended cost reports for S-10 revisions to be included in the

NPR

Settlements due by October 2018 (90%) and April 2019 (10%)

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SSI Update

• FY ‘04 and prior – CMS has published the SSI ratios; NGS is

awaiting CMS instruction for processing the open cost reports

• 15 NY PPS providers being held (9/28/99, 12/31/00 - 12/31/04, 06/30/05

FYEs)

• Hope to NPR in 2018/early 2019 as CMS finalizes timeframes

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Passwords

• Per CMS regulations, passwords that NGS encrypts files with can

no longer be communicated via email

• NGS associates will call providers with the password used

• NGS letter accompanying PS&R detail reports instructs providers

to call Amanda Schultz (315-442-4563) for the password

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Letters going out to Providers

• A provider may request changes to the Medicare cost report data from the time of

initial filing to be considered in the final settlement. All requested changes, unless

directed otherwise, must be made by submitting an amended cost report. NGS

will consider accepting the submission of an amended Medicare cost report so

long as it is prior to the start of the desk review (i.e. when the Medicare auditor

begins their audit analysis of the cost report filed data). An exception to this

would be if CMS were to issue a subsequent deadline for specified cost report

revisions

• To aid certain provider types on the projected deadline to amend, NGS may send

an initial request letter

• A listing of providers along with the applicable due dates that have received the

letters can be found out on our website under Cost Reports -> Amending

Medicare Cost Reports Prior to Desk Review

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Miscellaneous submissions

• GME Affiliation Agreements 42 CFR 413.79(g)

• 42 CFR 413.79(g)

• One email with agreement attached to both CMS and MAC

• CMS: [email protected]

• NGS: [email protected]

• 7/1/18-6/30/19 agreements due by 7/1/18

• 7/1/17-6/30/18 amended agreements due by 6/30/18


Miscellaneous submissions

• Temporary teaching cap adjustment requests for displaced

residents

• 42 CFR 413.79(h) and (i)

• Email or through Connex to:

[email protected]

• Requests to change statistical basis or order in which general

service costs are allocated CMS

• CMS Pub. 15-1 Section 2312 and 2313

• Email or through Connex to:

[email protected]

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2019 Wage Index Next Round


FY 2019 Wage Index Update

• April 5, 2018 – Deadline for hospitals to appeal MAC

determinations and request CMS’ intervention

• Data that was incorrect in the preliminary or January wage index data PUFs, but for which no correction request was received by the February 16, 2018 deadline, will not be considered for correction at this stage

• Early April 2018 – Final FY 2019 wage index data compiled and

sent by CMS to MACs for verification

• April/May 2018 – Approximate date proposed rule will be published

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FY 2019 Wage Index Update

• April 27, 2018 – Release of final FY 2019 wage index and OM data

on CMS website

• May 30, 2018 – Deadline for hospitals to submit correction requests

to both CMS and their MAC to correct errors due to CMS or MAC

mishandling

• August 1, 2018 – Approximate date for publication of FY 2019 final

rule

• October 1, 2018 – Effective date of FY 2019 wage index

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Cost Report Filing

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Cost Report Acceptance

• Cost Report acceptance is handled in our South Portland, Maine

office

• Courier Service (Fed Ex, UPS, etc.) Street Address:

• National Government Services

Attn: Cost Reporting Unit

2 Gannett Drive

South Portland, ME 04106

• Post Office Box Address - for Regular USPS Mail only:

• National Government Services

Attn: Cost Reporting Unit

PO Box 9731

Portland, ME 04104

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Cost Report Submission Methods

• NGS Connex – https://Connex.ngsmedicare.com-

Providers are encouraged to use the Web Portal to submit

requested information to NGS electronically

Advantages

Confirmation of receipt provided by Connex, along with follow up email acknowledging

receipt

No need to encrypt PHI/PII

Submission is instantaneous

Save shipping time and cost & is more secure than shipping

Connex can accept all documents types including ECR & PI files

Additional Requirement

Worksheet S with an original signature must be sent via the regular mail

The cost report is not considered received until worksheet S with an original signature

is received via the mail

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https://connex.ngsmedicare.com-/


Cost Report Submission Methods

• Cost Report filing email box

• [email protected]

• The mailbox is used for cost report filing questions and/or cost

report file/supporting documentation submissions, including

passwords

• All types of cost report files can be sent to the mail box including

EC & PI files

• PHI must be encrypted

• Mailbox is monitored, should receive a response the same day

• Worksheet S with an original signature must still be sent in

the mail

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New Lockbox for Checks

Mailing Address:

National Government Services, Inc.

PO Box 809366

Chicago IL 60680-9366

Courier Address:

US Bank

Attn: Lockbox No 809366

5635 South Archer Avenue

Chicago IL 60638

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Common Cost Report Submission Issues

• No signature or not an original signature on Worksheet S

Recommend signing in blue ink

• The CD or thumb drive has an executable program to gain

access to the files. We cannot open executable files

• Multiple cost reports are filed in one package

Include a cover letter identifying the different cost reports

filed together

• CD or thumb drive blank or broken

Include a cover letter with a POC so we can contact you

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Common Cost Report Submission Issues

• Incorrect Fiscal period; incorrect subunits included on CR –

review your reminder letter

• Filing late – results in payment suspension

• File early – if cost report is rejected, will receive grace period to re-

submit prior to payment suspension being initiated

• Cost Report Receipt Date is date signed Worksheet S is received.

Postmark date is used to determine interest assessment for late-filed

cost reports

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Amended Cost Report Submissions

• Amended submissions have the same cost report filing

requirements and follow the same acceptance process as

initial submissions

• Amended cost reports should be filed on the most recent

software version

• Normally, amended cost report requests are accepted if the

desk review has not started

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Cost Report Filing Resources

• [email protected]

• Lead – Bobbi Jo Luciano at: [email protected]

• PS&R - [email protected]

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mailto:[email protected]


•

Other miscellaneous Contact Information

ERP Fax

1-315-442-4140


ATTN: ORU Part A – ERS Requests

P.O. Box 809366

Chicago, IL 60680-9366

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Credit Balance Fax

CT/NY 1-315-442-4258

ME, MA, RI, RHHI: 1-315-442-4009

NH, VT: 1-315-442-4008


Part A ORU/Credit Balance Reports

P.O. Box 7071

Indianapolis, IN 46207-7071

Interim Rate Reviews

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Interim Rate Reviews

• Now one bad debt rate review per year

• With tentative settlement

• Potential increase in lump sum activity

• Maintain your records for cost report filing

• PIP providers

• Four PIP reviews per year

• If you have information for 2018, send with cost report or send via email to

[email protected] at time of cost report submission


Medicare Cost Report E-Filing System (MCReF)

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Medicare Cost Report E-Filing System (MCReF)

• As part of the Centers for Medicare & Medicaid Services (CMS)

commitment to decrease the hours and dollars providers spend on

CMS-mandated compliance and increase the proportion of tasks

that CMS customers can do digitally, a new web portal will be made

available to submit a Medicare Cost Report (MCR)

• Specifically, Part A providers will have the option to electronically

transmit their MCR through the Medicare Cost Report E-Filing

(MCReF) system. MCReF will be available for cost reporting

periods ending on or after December 31, 2017

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MCReF System Overview

• System will be hosted at the following URL: https://mcref.cms.gov

• System access is controlled by Enterprise Identity Management (EIDM)

• Access will be restricted to EIDM PS&R Security Officials (SO) / Backup Security

Officials (BSO)

• Existing PS&R SO / BSOs will already have access

• Any organization without access to PS&R will have to register a PS&R SO with

EIDM

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https://mcref.cms.gov/


“True” E-Filing is now possible

• Currently, at least some portion of a provider’s cost report submission MUST

come via the mail or hand-delivery

• CMS issued 2018 IPPS final rule in August 2017 authorizing providers to file with

an electronic signature effective for FYEs on/after 12/31/2017 – eliminating the

requirement for usage of mail / hand-delivery

• Note: Not all MCR transmittals supporting E-signature have been released. This should occur

over the next several months. Until then, Providers filing on MCR Versions which do not yet

support E-signature can still upload a scanned “Signed Certification Page” but must still send a

hard copy with a signature signed in ink to the MAC

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CMS MCReF Edits

• E-Filing Submission:

• The system will execute “receivability” validations confirming the provider’s

MCR is fundamentally sound

• If any error is triggered, the provider’s MCR will not be received in STAR

• This is not considered a cost report rejection as this cost report remains unfiled

• If no error is triggered, the provider will be presented with a Success message

(detailing their E-postmark date and unique E-Filing ID) and the cost report will

be considered “received” in STAR

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MCReF Additional Details

• Provider will be warned if:

• MCR submission is late

• Attempt to upload with MCR generated with outdated MCR software

• Files uploaded are not to be encrypted or password protected

• Exceptions that may need to be mailed or hand-delivered:

• Any other MCR that would satisfy CMS’ Acceptability Criteria but would not pass the “Receivability” checks must be filed via the mail or hand-delivery (e.g., a submission with more than 300 MB of “Other” documentation)

• Providers will not receive an extension for any system issues preventing E-Filing

• Only 2 CMS approved methods of MCR submission: electronic submission via CMS MCReF and physical submission via mail or hand-delivery

• MACs will not be allowed to receive cost reports via e-mail, MAC portal, or any other electronic submission method once fully implemented

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Processing of Provider’s E-Filed MCRs

• “Postmark Date”: automatically set by the system as the date / time (in ET) that the

provider’s MCR was submitted and passed all “receivability” validations

• Eastern Time zone will be used for determining an E-Filed MCR’s timeliness

• Deadline for an E-Filed MCR will be 11:59 PM ET on the provider’s CR Due Date

• Not editable by the MAC

• “Received Date”: the date that the provider’s MCR was received in STAR

• STAR will automatically set this date based on the following rules:

• For MCRs filed on a federal business day prior to 3 PM ET, this will be set to the

same date as the Postmark Date

• MCRs filed any other time will be set to the date of the next federal business day

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Advantages of MCReF for Providers

• One consistent process for all providers to follow via one cost report submission portal

• Large provider chain organizations will electronically submit MCRs to one system instead

of transmitting their MCRs to their assigned Medicare Administrative Contractor (MAC)

portals or physical mailing addresses

• Providers will receive immediate feedback on the submission accuracy of their MCR

• Providers will save time compiling the hardcopy files needed to create electronic media

and mail the MCR package

• Providers will have until 11:59 p.m., eastern time, on the due date to submit the MCR

instead of having to obtain a postmark date no later than the due date

• MCReF has a simple, straightforward user interface with just one screen

• Centralized data analysis leads to consistency for all providers in the receipt process

regardless of the MAC

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Advantages for MACs

• Directly retrieve all provider E-filed materials from STAR

• Reduction in MAC Data Entry and Manual Processes

• Removes need to manually enter Postmark & Received Dates into STAR

• Allows MACs to receive all cost report submission data

electronically (no original signed W/S S sent via mail)

• Allows MACs to store cost report submission data electronically

and eliminate hard copy paper storage

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CMS Current Rollout Plan

• Provider Testing - 2/28/18 to 3/6/18

• Outreach and education - 2/28 to 5/28

• MCR Vendor Webinar (KPMG)

• CMS website posting

• Provider Change Request

• Medicare Learning Network Connects Article

• Provider Webinars (3, potentially more)

• Documentation Updates (e.g.: 100-06, PRM 15-1 and 15-2, MCR Transmittal

Forms, etc.)

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Medicare Cost Report Reopenings

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Reopenings

• References

• 42 CFR 405.1885

• CMS Publication 15-1, Section 2931

• NGS website recently updated

www.ngsmedicare.com – Cost Reports – Submitting a Cost Report

Reopening

• Includes electronic and mailing address to submit reopening request

• Includes guidance on what to include in the request

• Includes guidance on how NGS evaluates the reopening request

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http://www.ngsmedicare.com/


Reopenings

• Submission options listed in order of preference

• Email: [email protected] (can request reply to confirm

receipt)

• Ensure PHI/PII is encrypted and share password separately

• NGS Connex portal (will receive automated response when successfully uploaded)

• Connex is a secure portal, do not encrypt files containing PHI/PII

• Mail (address next slide)

• Reduce paper by placing support on electronic media (i.e. CD, flash drive, etc.). Ensure

electronic media containing PHI/PII is encrypted and share password separately

• DO NOT SUBMIT DUPLICATE REQUESTS (i.e. a copy in email/Connex, and another

copy in mail, etc.)

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Reopenings

• Mailing address

• Regular Mail


Attn: Cost Report Reopenings

P.O. Box 9731

Portland, ME 04104

• FEDEX or Courier ONLY


Attn: Cost Report Reopenings

2 Gannett Drive

South Portland, ME 04106

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Reopenings

Submission should include:

• Cover letter or body of email identifying the following:

• Medicare provider name, 6-digit provider number, and cost report fiscal year

end

• Clearly specify the issue(s) requested to be reopened and why it meets the

conditions to qualify

• Include estimated reimbursement dollar impact

• Include requested adjustments to the cost report (i.e. w/s, line, column, and

amount for each adjustment

– Only include adjustments to direct input fields, fields that automatically

calculate as they flow through the cost report do not need to be included

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Reopenings


• Supporting documentation as applicable

• Not required to submit all supporting documentation if extensive

– Example: If requesting additional Medicaid eligible days for DSH as a result

of new data, the listing of days should be submitted, however source

documentation for each claim such as the Uniform Bill is not necessary

– All supporting documentation must be readily available to supply timely

upon request

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Reopenings


• Copy of previous NPR letter for which the reopening is being requested

from

• NGS will not deny the request if provider cannot locate and supply. NGS will compare to

our records. To reduce administrative burden: Please do not request copy of NPR letter

from NGS in effort for it to be included in the submission

• Reopening request should be made directly by the provider

• If request is made by third party, it must be endorsed in writing by the provider. Request

would need to include a letter on provider’s letterhead signed by an authorized contact at

the provider. The reopening request will not be valid unless endorsed by the provider

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Reopenings

Reopening criteria:

• The request must be received within three years of the notice of

intermediary hearing decision, determination of final settlement (i.e. date of

NPR letter), or Provider Reimbursement Review Board decision

• There must be new and material evidence submitted, or a clear and

obvious error was made, or the previous determination is found to be

inconsistent with the law, regulations and rulings, or general instructions

• The reopening request should include an explanation as to why the provider believes

these conditions are met

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Reopenings

Reopening evaluation process:

• It is the contractor’s discretion on whether or not reopen the cost report as

requested by the provider. Determinations are made case by case

• To be a clear and obvious error

– Has to be conclusive and easily verifiable. This would be based on either the

information supplied in the request and/or based on the information that NGS has

readily available. Common examples relate to errors the contractor made in settling

the cost report (i.e. mathematical or data entry error). Generally, issues that require

further audit testing by the contractor and were not claimed as part of a cost report

filing do not fall into this criteria

• To be new and material

– To be new evidence, there must be evidence that the data is new. This means the

data was not available at the time when the provider filed the cost report, nor at the

time of a subsequent due date in which there was an opportunity to amend the cost

report

– NGS will determine if it meets the criteria of being material as part of the evaluation

process

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Provider-Based Requests

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Provider-Based Attestations

• A request for Provider-Based status continues to be voluntary

• Submission in PECOS of the location is needed to begin the process. (Main provider’s name on

attestation should match the PECOS record)

• There are on campus and off campus provider based locations

• Review of off campus provider based locations will include financial integration, facility being held out

to the public as part of the main facility and beneficiary coinsurance information

• Information on filing a provider based attestation is included on our website an NGSmedicare.com.

Attestations and documentation can be submitted to [email protected]

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Questions

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Documents

JK Audit & Reimbursement Update - HFMA Central New York ... · •FY 2014 SSI NPR’s due by May 31, 2018 (only applies to desk reviews not audits) 90% NPR’d or sent for processing