Jeannine LeCompte, Publishing and Research Coordinator
Skilled Nursing Facilities (SNFs) are legally obligated to ensure that their cost reporting systems are in compliance with the Centers for Medicare & Medicaid Services (CMS) regulations.
In this regard, all records must be kept in agreement with generally accepted accounting standards or other applicable standards, and all transactions, payments, receipts, accounts, and assets are to be completely and accurately recorded on a consistent basis.
CMS requires Medicare-certified institutional providers to submit an annual cost report to a Medicare Administrative Contractor (MAC). The cost report contains provider information such as facility characteristics, utilization data, cost and charges by cost center (in total and for Medicare), Medicare settlement data, and financial statement data.
CMS stores this cost report data in the Healthcare Provider Cost Reporting Information System (HCRIS). Ensuring that the correct data is provided to CMS is the responsibility of SNF employees and contractors, and a failure to maintain standards can, and will, lead to severe penalties.
All employees and contractors are expected to maintain honest and accurate records of services provided, follow all current and applicable laws, regulations, and guidelines, fully document all services, and take all necessary steps to prevent the submission of claims for payment and reimbursement of any kind that are fraudulent, abusive, inaccurate, or medically unnecessary. A full investigation and report must be completed within six months.
All aspects of the cost calculation process should be reviewed and certified. For example, all claims for therapy and skilled interventions must agree with the service and census logs, and all physician certification/recertification forms should be completed in full and signed by the ordering physician.
The administrative process must ensure that the accurate recording (charting) of treatment and responses is completed at least once every 24 hours. These records are required to be kept intact and ready for inspection for at least six years.
Should any errors be detected, the provider has a 60-day grace period to report the mistake and take all necessary steps to ensure that it is corrected. A failure to report within this 60-day period—which is counted from the date of detection—carries with it a presumption of bad faith.
Cost reports are due on or before the last day of the fifth month following the close of the cost reporting period. For cost reports ending on a day other than the last day of the month, cost reports are due 150 days after the last day of the cost reporting period. There are no extensions granted to this rule except in the case of “extraordinary circumstances” over which the provider has no control (such as a fire, flood, or other disaster).
