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Stay up to date with the latest information on Medicare regulations and cost report submission. This material provides valuable insights for healthcare providers.
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JK Audit & Reimbursement Update April 8 - 12, 2019
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.
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
Agenda • Cost Report Acceptance • MCReF - Medicare Cost Report E-Filing System • Interim Rate Reviews • A&R Inquiries in NGS Connex • Amending a Medicare Cost Report prior to the Desk Review Start Date • Jurisdiction K Audit Workload • Worksheet S-10 Reviews • Nursing and Allied Health – Legal Operator • Standard Charges Requirement • Medicare Cost Report Reopenings • Misc. Contact Information • Questions
Cost Report Submission • Effective July 2, 2018, there are only twoCMS-approved methods of Medicare cost report submission: • Electronic submission via MCReF • Physical submission via mail or hand-delivery • Cost reports can no longer be submitted via NGS Connex or via email • This includes submission of cost report files needed for Acceptance – IRIS files, EC/PI files, etc. These must be submitted via MCReF or mailed on a CD/thumb drive • Please include a contact person (phone and email) that can be contacted regarding any submission issues, passwords, etc. The contact person should be someone with knowledge of the cost report filing.
Mailing Address • Cost Report acceptance is handled in our South Portland, Maine office (The preferred method for filing cost reports is MCReF) • 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 • Cost Report filing email box (for inquiries ONLY) • JK_cost_report_filing@anthem.com
Mailing Address - Checks • Checks should be sent to our lockbox at the same time the Cost Report is submitted. They are sent to our bank lockbox at the address below: • Regular Mail: • National Government Services US Bank Lockbox Services - JKA PO Box 809366 Chicago, IL 60680-9366 • FedEx or Courier only: • US Bank Attn: Lockbox 809366 5635 South Archer Ave Chicago IL 60638
Common Cost Report Submission Issues • Worksheet S signature not valid • Original signature – recommend signing in blue ink • Electronic signature – check the box on Worksheet S, include first and last name, title, and date • Multiple cost reports are filed in one package • Include a cover letter identifying the different cost reports filed together • For mailed submissions, CD or thumb drive blank or broken • The CD or thumb drive has an executable program to gain access to the files. We cannot open executable files • Include a cover letter with a POC so we can contact you
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, but does not determine timely filing • If cost report is filed late resulting in payment suspension, payments are released once cost report is received AND accepted.
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 • MCReF can be used for FYE 12/31/2017 and later. If FYE is prior to 12/31/2017, amended cost report must be submitted via mail
Cost Report Filing Resources • Questions: JK_cost_report_filing@anthem.com • Lead: Bobbi Jo Luciano - Bobbi.Jo.Luciano@anthem.com • PS&R - PSR@anthem.com
Medicare Cost Report electronic Filing (MCReF) MCReF –High Level System Overview • New application - allows providers to electronically transmit (e-File) your Medicare Cost Report package • Effective 5/1/18 for cost report with FYE 12/31/2017 and after • Usage is optional. Mail and hand-delivery remain filing options. • NGS Connex/email are no longer filing options • System Login: https://mcref.cms.gov • Accessible by your EIDM PS&R Security Official (SO) and Backup Security Official (BSO)
Medicare Cost Report electronic Filing (MCReF) Advantages of MCReF for Providers: • Single, easy-to-use webpage • One process for all providers via one submission portal • Available to all Part A providers regardless of MAC • Beneficial to chain organizations which have providers at multiple MACs • Reduces confusion, delays, and time spent on administrative processes • Immediate feedback on receivability of MCR submission
Medicare Cost Report electronic Filing (MCReF) MCReF Overview • System Login: https://mcref.cms.gov • Access controlled by EIDM. Restricted to EIDM PS&R SO / BSO • Existing PS&R SOs / BSOs already have access. • Any organization without access to PS&R must register a PS&R SO with EIDM. • https://portal.cms.gov • Note: If you want to use MCReF, keep your EIDM SO and BSO accounts in good-standing. Includes password updates and timely replacement of SOs. • EIDM credential issues are not a valid reason for late MCR filing.
Medicare Cost Report electronic Filing (MCReF) MCReF Additional Details • Effective 7/2/2018, only 2 CMS-approved methods of MCR submission: • Electronic submission via MCReF • Physical submission via mail or hand-delivery • Providers will not receive an extension for system issues preventing e-Filing. • Additional information is available on the CMS web site including a video training presentation and FAQs • https://www.cms.gov/Medicare/Compliance-and-Audits/Part-A-Cost-Report-Audit-and-Reimbursement/MCReF.html • NGS has developed two YouTube videos to assist providers with the process.
Medicare Cost Report electronic Filing (MCReF) . NGS You Tube Video Links: • How to Access and Use the Medicare Cost Report e-filing (MCReF) System through the EIDM system • Part 1: https://www.youtube.com/watch?v=t8g6mtD_dig • How to Use the Medicare Cost Report e-filing System (MCReF) • Part 2: https://www.youtube.com/watch?v=uZqJ5ZnjKVw
Electronic Cost Report Signature • 2018 IPPS final rule issued in August 2017, authorizes providers to file with an electronic signature effective for FYEs on/after 12/31/2017. • Note: IPPS final rule does not change the authorized signatories (CFR §413.24(f)(4)(iv)(C)) • CMS released new MCR transmittals which support e-signature.
MCReF Filing Reminders • MCReF submission stands alone. All documentation should be uploaded. Do not also mail Worksheet S – Worksheet S with valid electronic signature is uploaded via MCReF • Exception – Home Office signed Worksheet A must be mailed with original signature • If a correction is needed, please include a cover letter requesting first submission be informally rejected. • One correction per day is allowed. • Corrections/resubmissions must consist of a full cost report filing (each MCReF submission stands alone) • Do not encrypt files uploaded via MCReF. MCReF is a secure system
Bad debt interim rate reviews • CMS only requires one rate review for bad debt per year. • GME, Organ and PIP require two rate reviews per year. • In JK NGS completes 4 PIP reviews per year • Bad debts will be reviewed during the rate review conducted at the time of tentative settlement. • Bad debts will not be listed on other rate reviews during the year. • Exception – Part B bad debts need to be included on the cover sheet noting “Pass” in order to calculate the ROE total correctly (total Part B bad debts) • Does not mean that bad debts are set to zero! It means it was not reviewed! • If bad debts were being set to zero, you would see a rate under the Old Rate Column and a $0 under the Calculated Rate Column, as well as a “Issue” on the cover sheet.
Example Rate Review with no bad debt review and distribute lump sums.
Example Rate Review with no bad debt review and issue lump sums.
Example Rate Review with bad debt review included and pass, issue and distribute lump sums.
Audit Adjustment Factors • During rate reviews and tentative settlements, historical data will be reviewed as well as any documentation supplied by providers to explain deviations from historical data. • Reimbursement associates may apply an audit adjustment factor to interim rates or tentative settlements as it is not audited data.
A&R Inquiries in NGS Connex • Enhancement to the NGS Connex Portal • Launched on October 5th • The Audit & Reimbursement team has been sending requests and correspondence to providers who have signed up. • Some examples of what might be sent: audit requests, interim rate letters, tentative settlements, adjustment reports, B-1 stat requests, final cost reports (NPRs) and PS&R Detail Reports.
A&R Inquiries in NGS Connex Benefits: • The NGS Connex portal is secure. • Transmission through A&R Inquiries in NGS Connex is safer, faster and cheaper than mailing by either the providers or NGS. • Documents are electronic. Some organizations share our documents with multiple people. Much easier when you receive them electronically
A&R Inquiries in NGS Connex Benefits (continued): • Correspondence can be sent to multiple contacts at once. Several people within your organization can be set up receive the notification emails via NGS Connex. • If you typically forward NGS A&R correspondence to another person within your organization, you will want to add them on to our initial distribution. An automated email is sent through NGS Connex to each person on the list for each transmission. You cannot simply forward the NGS Connex email to another person. That person you forward your email notification to may not be able to see the transmission even if they have NGS Connex accessbecause they need to be added to the specific inquiry.
A&R Inquiries in NGS Connex Benefits (continued): • Inquiries are never deleted. You can go back and view them at a later date within NGS Connex as long as you are on the inquiry. • 2- Way NGS Connex gives A&R and providers the ability to create an open dialogue together while sending & receiving documentation. • Currently attachments sent back to NGS must be added one at a time. We have an enhancement in the works to allow providers to attach multiple files at once. • There is no need to reply to the NGS inquiry that doesn’t request a reply with a due date unless you have a question or concern.
A&R Inquiries in NGS Connex Benefits (continued): • External users cannot initiate their own A&R NGS Connex inquiry. Only A&R can initiate an inquiry that an external user responds to. Providers would continue to use the My Financials section of full NGS Connex when submitting documentation that is not in response to an AR Connex inquiry. • A&R has administrative capabilities to setup external users (contacts) that are not already registered in AR Connex. These external users would only have access to the AR inquiry in AR Connex. • These people will not be able to take advantage of the other NGS Connex features.
A&R Inquiries in NGS Connex • What can you do? • Ensure your NGS contact information is correct • If A&R correspondence should be addressed (letter salutation) to someone other than the Authorized or Delegated Official on the 855A/PECOS, the AO or DO should e-mail ARConnex@Anthem.comwith the following information: • Designated Contact Name • Title (Manager & Above) • Phone Number • Mailing Address • Email(s) Address • Time Zone • Provider Numbers Impacted (6 Character PTAN)
A&R Inquiries in NGS Connex • What can you do? • If you are already registered with NGS Connex, send an email to ARConnex@anthem.com to let us know your ID and which provider number(s) to add you to the distribution for correspondence going forward. • If correspondence has already been sent to another individual at your facility via NGS Connex and you want to have it also sent to your NGS Connex ID, ask us to add your Connex ID to the inquiry. If you know the inquiry ID, that is the easiest. If not, if you know the date of the correspondence and the type (tentative, rate, final, etc.) then we can look it up.
A&R Inquiries in NGS Connex • NGS Connex will be the way we will be handling outbound correspondence for all providers once we complete the set up process. • It is not optional. • We have a dedicated shared email mailbox for inquiries related to using A&R Inquiries in NGS Connex: ARConnex@Anthem.com. • However, if you have technical issues with NGS Connex, those inquiries need to be directed to the NGS Customer Care at 1-888-855-4356. • If we are unable to locate an email address for a provider we are attempting to send correspondence to, we have developed a memo to include in the mailed package which describes NGS Connex and gives the providers information on how to get set up. • YouTube video with step by step instructions for utilizing AR Inquiries. News article posted 12/7/18 on NGS website: Now Available in NGSConnex - Audit and Reimbursement Two-Way Communication
Updating your 855A AO/DO • Sections of the 855A that are required to be completed for an AO/DO change: • 1A- Provider will check the box “You are changing your Medicare information” and list their provider and NPI numbers • 1B- Provider will check the box that applies to what they are changing so if they are changing their AO they will check that box if it is DO then that box or both. They will check all that apply to them. • 2B1 -They will complete this entire section this applies to their business information • 3- They will check the box if Adverse legal Action applies to them or not • 6- This is Ownership Interest And or Managing Control Information (Individuals) they will compete this for the individuals that they are adding and deleting as the AO/DO. It may be several copies of this section depending on how many they are adding/deleting. • 13- Contact information (this is the person who is completing the application) and if we have any questions we know who to contact. • 15 and 16 is for the AO/DO to sign and date. Also need one completed for the individuals they are deleting but it is not required for them to sign and date if they are no longer there. Just like section 6 there may be several pages of this section completed depending on how many they are adding/deleting.
Amending a Medicare Cost Report Prior to the Desk Review Start Date
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 • The 2017 Cost Report deadlines are currently being addressed and plans are to have the excel spreadsheet updated by of 09/30/2019 or shortly thereafter.
JK Audit Workload- Option Year 5 • Option Year 6 - 3/1/2019 to 2/29/2020 • Approximate JK inventory (NY, CT, ME, MA, NH, VT, RI) • 425 Hospitals • 2,600 Other than hospitals (i.e. freestanding: SNF, HHA, ESRD, CORF, Home Office, etc.) • Medicare cost report audit Workload • Desk reviews (Currently finishing up FYE 2015s for SSI% directive, primary workload in OY6 will be 2016s) • OY 6 Audit Plan (98 total Audits – Many have already been started in prior period. 45 NY providers being audited in OY6) • HITECH Audits – No HITECH audits for OY6 • Final Settlements (including cases put on hold: FY 15 & 16 SSI, outlier reconciliations, S-10, Allina) • Wage Index (266 JK reviews. All reviews will be completed Sept- Nov. 2019) • Reopenings/Appeals • Medicare Secondary Payer audits (subcontracted to Systematic Billing again. There are 43 in total in JK. 20 NY providers selected this year)
On Site/Field Audits NGS On Site/Field Audits • NGS does still perform on site audits when deemed appropriate in the scoping of specific hospitals • Not nearly as common as in years past. Typically about 15-20% of providers selected for audit will get a Field Audit (vs. In House) • OY4 = 14/70 were Field Audits OY 5 = 12/72 Field Audits • NGS is completing 15 audits previously started on site during OY6. (No new Field Audits this year) • On Site audits typically take place at the larger JK providers in NYC (Figliozzi performs some of the NGS field audits as a subcontractor) or occasionally a Critical Access Hospital will be chosen to verify square footage and analyze cost issues, etc. • 20 total NY providers have been selected for Field Audit the past 3 years
SSI update Published September 2018 by CMS • FY 2015 SSI • 90% of NPR’s due by April 30, 2019 for NPR (only applies to desk reviews). The remaining 10% due by September 11, 2019. • 26 NY 2015 SSI have not been issued • Some held for Allina, PY audits still open, backlog • FY 2016 SSI • Held NPRs to allow for any wage adjustments to be included in final package (similar approach as last year). NPR’s are starting to be issued now and should pick up in summer/fall 2019 • 90% to be NPR’d by February 29, 2020. Remaining 10% due by April 30, 2020.
S-10 reviews • CMS mandated S-10 reviews be completed by January 31, 2019. • CMS selected 50 cost reports per Jurisdiction for review. • Inaugural S-10 reviews generated many questions / concerns resulting in multiple conversations with CMS. • Significant adjustments were proposed due to inaugural reviews. • Due to various reporting methodologies, CMS mandated a secondary review of specific items and if necessary, adjustments were issued.
S-10 reviews • CMS mandated secondary review to be completed 3-15-19. • Awaiting further information from CMS regarding the S-10 review impact on the final rule. • Future S-10 review instructions are pending.
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