Changes in the Cost Reporting Process
On December 19, 2003, the Centers for Medicare & Medicaid Services (CMS) issued a revision to Chapters 8, 9 and 10 of the Medicare Financial Management Manual. The instructions in this revision will have a significant impact on the manner in which WPS audits provider cost report.
CMS has instructed its contractors that after October 1, 2004 they will no longer perform focus reviews". All audit work performed on-site at the provider premises will instead be deemed a field audit", though contractors may perform a field audit of a single issue if they believe it s appropriate.
We will perform a desk review on any cost report that is not selected for field audit. If we believe it is necessary to request information or documentation as a result of the desk review, we will give you 3 weeks from the date of the request to furnish the information or documentation. If we have not received the requested information or documentation within this time frame, we will propose an adjustment to your cost report. We will send you any proposed adjustments, and you will have 10 days to respond in writing with any additional information or documentation. We must receive your response in 10 days. The proposed adjustments will become final after we make any necessary modifications based on your submitted information or documentation. We will accept information submitted after the 10-day time frame, but we will not consider this information in the initial Notice of Amount of Program Reimbursement (NPR). This additional information or documentation may be considered at a later date if we decide to reopen the cost report or if you file an appeal.
If we decide to perform a field audit" of your cost report, we will send you an engagement letter no earlier than 6 weeks and no later than 4 weeks prior to the first day of field work. The engagement letter will include the following.
- A list of the required documents that are to be made available on the first day of the audit.
- Date of the entrance conference.
- A request that you assign a contact person to be the audit liaison.
- A tentative pre-exit conference date set for the last day of fieldwork.
- A tentative exit conference date set approximately 3 to 4 weeks after all the outstanding documentation is furnished.
- Notice that all documentation and records requested prior to and during fieldwork must be furnished in a timely manner and that failure to produce documentation will result in non-negotiable audit adjustments.
- Notice that, as a general rule, we will not honor any reopening requests for lack of documentation" adjustments.
We will conduct a pre-exit conference on the last day of fieldwork or, if this is not feasible, on an agreed-upon date. At the pre-exit conference, we will give you a copy of all adjustments proposed to date and the supporting workpapers. We will also give you a written list of outstanding documentation that we requested but have not received and give you 4 additional weeks to submit the documentation. We will schedule the exit conference date - generally 3 to 4 weeks after the expiration of the 4-week period - so that we have sufficient time to review any additional documentation you submitted within the 4 weeks and resolve any disputes over new audit adjustments proposed after leaving your site.
At the conclusion of our review of your documentation, we will prepare and send you an audit adjustment report. Within 10 days of receipt of this report, you should notify us in writing of any concerns you have with the adjustments. We must receive your written notification within 10 days. We will also notify you that the audit adjustment report will become final after we make any necessary modifications based on your written concerns and documentation supporting them. We will accept information after the 10-day time frame, but we will not consider this information in the initial Notice of Amount of Program Reimbursement (NPR). This additional information or documentation may be considered at a later date if we decide to reopen the cost report or if you file an appeal.
We will schedule an exit conference unless you notify us in writing that you waive your right to one. At the exit conference, we will give you a copy of all audit adjustments and supporting workpapers. Since you had an opportunity to comment on all the audit adjustments during the pre-exit conference and during the finalization period, there should be no need to change them during the exit conference. We will not consider any additional documentation submitted at the exit conference in the initial NPR.
If you have any questions, please contact the Field Audit Manager who handles your cost report audit. Refer to our Field Office Contacts.
This publication was also issued in our June 15, 2004 Newsletter.
Page Last Updated: Tuesday, 15-Jul-2008 10:35:53 CDT
