Medicare Compliance & Reimbursement

Get your blue pen handy to avoid rejections.

 You shouldn’t be surprised to see your payments suspended if you don’t meet cost report and related requirements.

"On April 17, 2014, Palmetto GBA notified our provider community that quarterly Credit Balance Reports were due April 30, 2014," the Home Health & Hospice Medicare Administrative Contractor says on its website.

"Suspension Warning Letters were mailed stating that suspension of all claims payments at 100% would begin in 15 calendar days from the date of issuance of the letter if the credit balance report is not received during this time period." The suspensions began with June 3 Remittance Advices, Palmetto notes. "This suspension will continue until the credit balance report is received."

Plus: Cost reports for years ending Dec. 31 were due June 2, Palmetto adds. "For cost reports not received, a first demand letter is issued that initiates a payment suspension," the MAC explains. For the Dec. 31 year-end cost reports, Palmetto mailed the letters June 9 and began penalty suspensions for Remittance Advices dated June 12.

This isn’t anything new, points out cost report expert Tom Boyd with Simione Healthcare Consultants in Rohnert Park, Calif. "I suspect they put it in writing due to [a] great number of inquiries they were getting from new providers (and old) that failed to file or had a rejected cost report," Boyd tells Eli.

Another wrinkle: Increased inquiries may be due to agencies’ lack of information. "We are seeing a number of HHAs that have started hospices that have made a mistake in the status of the hospice," Boyd explains. "This is causing rejected hospice cost reports or overdue cost report requests being made for the late or missing hospice cost report."

In other words, "the HHA ‘forgets’ to tell the MAC that they wish their new hospice to be HHA-based (within one cost report) and not a free standing hospice (two cost reports)," Boyd says. "The MAC sends out letters that the hospice cost report is overdue as the MAC does not know (or look) that the hospice was filed with the HHA."

Some hospices likely have filed a separate cost report, even while they intend to be HHA-based, because they don’t even know about the possibility of being within the HHA cost report, Boyd adds.

Tip: A number of common errors are resulting in returned cost reports and suspensions, notes the Hospice Association of America (HAA) in a message to members. For example, "although some provider types now have the Form CMS 339 Questionnaire incorporated in their cost reporting form, home health agencies and hospice providers are still required to file a separate Form CMS 339," notes HAA, an affiliate of the National Association for Home Care & Hospice. "As with the cost report, the form must be signed by the administrator or officer of the facility."

Because electronic signatures or photocopies — including facsimiles — are not permitted, the officer or administrator should sign the certification page (Worksheet S) that contains the ECR and PI encryption codes using blue ink, some MACs recommend. "The Cost Report Questionnaire (CMS-339) certification page should also be signed in blue ink to clearly indicate that the signature is original," HAA says.