Filing of Short-Form Cost Reports
Regulation for filing a Low Utilization Cost Report
The Centers for Medicare and Medicaid (CMS) allows intermediaries to authorize less than a full Medicare cost report if a provider has low Medicare utilization in any given cost reporting period (refer to CMS Provider Reimbursement Manual (PRM) 15-2, Section 110). Based on the intermediary's knowledge of the provider's Medicare utilization and interim payments as reported in the Provider Statistical and Reimbursement Report (PS&R), the intermediary will advise the provider if a low Medicare utilization cost report may be filed. However, regardless of the low Medicare utilization or the amount of aggregate interim reimbursement, the intermediary may require full Medicare cost reporting and auditing if necessary to serve the best interests of the program. Providers must submit the forms and data under this alternate procedure within the same time period required for full Medicare cost reports.
In accordance with PRM 15-1, Section 2414.4B, the qualifications to file for a low Medicare utilization cost report are based on the intermediary's knowledge of the provider's Medicare utilization and interim payments and the intermediary's conclusion that it can determine the reasonable costs of covered services. Accordingly, WPS requires the following requirements to request/file a low Medicare utilization cost report:
- During the cost reporting period, the provider's Medicare reimbursement for Part A and Part B total less than or equal to $100,000.
- During the cost reporting period, the provider's Medicare pass-through costs must be less than $5,000. (Pass-through costs are those services reimbursed in addition to prospective payment services, e.g. Medicare bad debts).
- The Medicare net reimbursement of $100,000 includes PS&R interim payment amounts, level payments and retroactive adjustments issued for that cost reporting period.
The thresholds will be prorated for providers requesting to file a low Medicare utilization report if the cost reporting period is less than 12 months. However, regardless of low Medicare utilization or the amount of aggregate interim payments, the intermediary may require full cost reporting and auditing if that is necessary to serve the best interests of the Medicare program. Therefore, requests for low utilization cost reporting will be evaluation on a case by case basis.
Provider s Responsibility - Making a Request
A request to file a low Medicare utilization cost report must be accompanied by a request for a waiver to submit an electronic file. This dual request must be made in writing no later than 30 days after the end of the provider's cost reporting period. This time frame is outlined in 42 Code of Federal Regulations (CFR) Section 413.24 (f) (4) (v), which states, A provider may request a delay or waiver of the electronic submission requirement in paragraph (f)(4)(ii) of this section if this requirement would cause a financial hardship or if the provider qualifies as a low or no Medicare utilization provider. The provider must submit a written request for delay or waiver with necessary supporting documentation to its intermediary no later than 30 days after the end of its cost reporting period. The intermediary reviews the request and forwards it, with a recommendation for approval or denial, to CMS central office within 30 days of receipt of the request. CMS central office either approves or denies the request and notifies the intermediary within 60 days of receipt of the request."
As required by 42 CFR 413.24, the intermediary will review each request and forward them to CMS Central Office with a recommendation for approval or denial. For provider requests received in the time frame outlined above and whose Medicare utilization meets the aforementioned threshold requirements, WPS will notify the provider of the approval to file a low Medicare utilization cost report. If the provider request is not received within the aforementioned time frame, the request to file a low Medicare utilization cost report will be denied.
Filing Requirements
To file a low Medicare utilization cost report, WPS requires that the provider submit all of the following information:
- Cost report worksheet S, A and G series (including worksheets (S-2, S-3, S-7, A-6, etc.) as applicable and worksheet C from the CMS approved cost reporting forms.
- The working trial balance including the balance sheet and statement of income and expense
- A completed Form CMS-339 and all required supporting documentation
- Other financial and statistical data including, when available, any financial reports prepared by an independent reviewer that WPS may deem appropriate depending upon the circumstances of the individual case.
The filing of a low Medicare utilization cost report eliminates the cost report worksheets that allow for overhead allocation to the participating cost centers. If a provider is receiving cost based reimbursement for a sub-unit or cost center or the provider wants overhead allocated to ancillary cost centers, a full Medicare cost report must be filed.
Acceptability Process
During acceptability of the as-filed cost report, WPS will determine if the cost report filed has met the low Medicare utilization threshold guidelines. If the cost report meets WPS's low Medicare utilization guidelines, the cost report will be accepted and a Notice of Program Reimbursement (NPR) will be issued with net reimbursement equal to interim payments. However, if a cost report does not meet the low Medicare utilization threshold guidelines, it will be rejected and the provider will be required to file a full Medicare cost report and will be placed on withhold until an acceptable cost report is received. The provider will not be granted additional time to file an acceptable cost report.
If you have any questions regarding this process, you may contact the Audit Supervisor assigned to your facility. Refer to our Home Office Contacts for names and extensions.
This information was also provided in our Medicare Newsletter dated August 15, 2004 .
Page Last Updated: Tuesday, 15-Jul-2008 10:37:29 CDT
