Cost reports may have taken a back seat to more pressing issues under the prospective payment system, but it's still important to accurately document the costs you claim in your annual cost report. If you don't, you could face fraud and abuse charges from Medicare. "CMS has NOT changed cost reporting requirements, nor have the cost reimbursement regulations been changed," stresses consultant Tom Boyd with Rohnert Park, CA-based Boyd & Nicholas. Home health agencies "are supposed to conform to the requirements and can be held liable under the false claims act for misinformation or improper costs in the cost report," he warns. Or your costs could be drastically reduced by intermediary auditors. Under PPS, such disallowances won't lead to a direct reimbursement impact on an HHA as it did under the cost-reimbursed system. But when the government looks at aggregate cost data for the industry, such disallowances will make it appear agencies are making a large profit when in fact they may just be breaking even. "Just as clinical documentation is important to a patient's health and file, so is financial documentation vital to a home health agency's Medicare reimbursement," Boyd says. He advises HHAs to "think 5WRT" when documenting their costs: who, what, when, where, why, receipt and time. For example, Boyd says, in claiming reimbursement for lunch at a utilization committee review meeting, cover these documentation bases shown in the chart.