Medicare Audit & Reimbursement Update

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8/20/2018 1 Medicare Audit & Reimbursement Update Presented by Kim Hitzemann 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 .

Transcript of Medicare Audit & Reimbursement Update

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Medicare Audit &

Reimbursement Update

Presented by Kim Hitzemann

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.

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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

• General Organization Update and Contact Information

• MAC Jurisdictions

• PS&R Redesign and Cost Report Update

• HITECH

• Audit Issues

• Provider Based Determinations/Mid Build

• Other Topics/NGSConnex

• Q&A

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NGS J6 A&R Offices

• We now have one Audit & Reimbursement staff that serves all of the J6 providers.

• Gary Lukuc manages the team that works on desk reviews, audits and wage index.

• John Stoll manages an audit team and the team that works on Reimbursement activity including tentative settlements, interim rate reviews, Provider Based Determinations, etc.

• John and Gary report directly to Gene Nickerson.

Cost Report Mailing Address

• Street Address:National Government ServicesAttn: Cost Report UnitP.O. Box 9731Portland, ME 04104

FEDEX or courier only:National Government Services, Inc.Attn: Cost Report Unit2 Gannett DriveSouth Portland, ME 04106

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Lockbox for Checks

Mailing Address:National Government Services, Inc.

PO Box 809199

Chicago IL 60680-9366

Courier Address:US Bank

Attn: Lockbox No 809199

5635 South Archer Avenue

Chicago IL 60638

J6 A&R Mailing Address

National Government Services

8115 Knue Rd

Indianapolis, IN 46250

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Standard Mailboxes

Cost Report Filing

Cost Report Re-openings

Cost Report Appeals

Provider Based Determinations

PS&R

Hospice Caps

[email protected]

[email protected]

[email protected]

[email protected]

[email protected]

[email protected]

Part A Audit & Reimbursement:

NGS Subcontractors

• Kujawa & Batteau (Desk reviews and Audits)

• Medaccountants (Desk reviews and Audits)

• Figlozzi & Company (Desk reviews and Audits)

• Systematic Medical Billing & Credentialing (MSP Audits)

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Other Miscellaneous Contact

Information

Credit Balance

1-315-442-4287

Connex Submission

National Government Services, Inc.

Attn: ORU/Credit BalanceP.O. Box 6474

Indianapolis, IN 46206-6474

ERP

Fax: 414-459-6007

National Government Services, Inc.

ATTN: ORU Part A – ERS Requests

P.O. Box 809199

Chicago, IL 60680-9199

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MAC Jurisdictions

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MAC Jurisdictions

• MAC J6 which includes the states of Wisconsin, Illinois, and Minnesota was awarded to NGS.

• MAC J6 Part A WI, IL, HHH transitioned on 7/13/13.

• MAC J6 Part A MN transitioned on 8/10/13

• MAC J6 Part B transitioned on 9/7/13

• CMS has slowed on super MAC transition.

• Under recent legislation contracts are going to be for up to 10 years instead of 5 years.

• CMS has extended NGS 2 years and 5 months for MAC J6. (Now through May 31, 2020.)

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Jurisdictions for A/B MACs

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PS&R/Cost Report

Update

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PS&R Redesign

• The system which controls your PS&R user ID (formerly IACS) is EIDM.

• The internet address for accessing PS&R is included below. (https://psr-ui.cms.hhs.gov/psr-ui,

• PS&R Summary data can be requested on-line.

• PS&R detail can be requested on-line and will be sent via CD. First detail request is free.

Passwords

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• Passwords that NGS encrypts files with can no longer be communicated via email.

• NGS associates will call providers with the password used.

• NGS letter accompanying PS&R detail reports instructs providers to call Lisa Beatty (414-877-0018) for the password.

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• 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

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Electronic Cost Report Signature

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Electronic Cost Report Signature

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Medicare Cost Report

electronic Filing (MCReF)

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MCReF –High Level System Overview

• A new application allows providers to electronically transmit (e-File) your MCR package Available as of 5/1/2018

• Usage is optional. Mail and hand-delivery remain filing options.

• Accessible by your EIDM PS&R Security Official (SO) and Backup Security Official (BSO)

• Your MAC will have access to e-Filed cost report materials

Medicare Cost Report electronic

Filing (MCReF)

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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, and any time you change MACs

• Reduces confusion, delays, and time you spend on administrative processes

• Immediate feedback on the receivability of your MCR submission. 23

Medicare Cost Report electronic

Filing (MCReF)

MCReF Overview

• System Login: https://mcref.cms.gov• Access is 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.– 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.

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Medicare Cost Report electronic

Filing (MCReF)

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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 website including a video presentation. 25

Medicare Cost Report electronic

Filing (MCReF)

Common Cost Report Submission

Issues

• No signature on worksheet S or signature is not original

Recommend signing in blue ink

• The CD or thumb drive has an executable program to gain access to the files. We cannot open executable files.

• Multiple cost reports are filed in one package.

Include a cover letter identifying the different cost reports filed together.

• CD or thumb drive blank or broken

Include a cover letter with a POC so we can contact you.

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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.

Amended Cost Report

Submissions

• Amended submissions require the same documents 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.

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Audit Update

SSI Update

• FY 2015 SSI Published July 2017 by CMS

Held NPRs through wage index season to allow for any wage adjustments to be included in final package (similar approach as last year)

This also allowed any amended cost reports for S-10 revisions to be included in the NPR

Settlements due by October 2018 (90%) and April 2019 (10%)

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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 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

Reopening's

• NGS continues to use a dedicated reopening team to review and process reopening requests.

• This has resulted in more consistency on reopening decisions throughout NGS.

• Reopenings or correspondence relating to reopenings can be submitted to NGS at the following mailbox. [email protected]

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Reimbursement

• Tentative settlements are completed within 60 days of acceptance.

• Interim rate reviews are completed twice a year for CAHs

• Requests for additional interim rate reviews should be rare and are generally done within 30 days of receipt. This can be delayed during high cycle periods.

Provider Based Attestations

• A request for Provider-Based status is voluntary.

• Submission in PECOS of the location is needed to begin the process. (Main provider’s name on attestation should match the PECOS record.)

• There are on campus and off campus provider based locations.

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Provider Based Attestations

• The financial operations of all locations of the organization must be integrated into the financial system of the main provider.

• A copy of the main provider’s chart of accounts and a copy of the main provider’s working trial balance are needed.

• All department cost centers are listed properly on the cost report.

• The clinic can be traced to an appropriate cost center on the cost report.

Provider Based Attestations

• The provider based facility is held out to the public as part of the main provider.

• When patients enter a provider based facility they are entering the main provider and billed accordingly.

• Beneficiary co-insurance policy must include information regarding providing the notice to the beneficiary’s authorized representative.

• Beneficiary co-insurance notice must include the estimate of actual cost for the visit.

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Calculators and Fee Schedules

• Providers can find pricing information for various Medicare rates including IPPS, OPPS, fee schedules by going to the link on our web site.

• The page is titled Fee Schedules and Pricers

• Can be timing issues with updates

• Most link to CMS Pricers

• Providers can check IPPS payments on DDE disclosure screen

Connex Provider Portal

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What is Connex?

• Secure web portal providers may use to deliver information and documentation to NGS.

• Currently in use by other NGS functions.– Claim status, Beneficiary eligibility, Financial

data, Provider demographics, order remittances

• More secure than shipping, no need to encrypt PHI/PII.

• Submission is instantaneous.

• Save shipping time and cost.

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Two Way Connex

• Development for two way portal is under way.

• For those providers that are signed up for Connex all A&R correspondence can go through the portal once implemented.

• So for example interim rate letters, tentative settlements, adjustment reports and even final cost reports.

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Contact Information

• John Stoll, Audit & Reimbursement Manager 262-202-6053 [email protected]

• Kim Hitzemann, Audit & Reimbursement Lead

262-456-7122 [email protected]

Questions?