OHCA/CGS Meeting
November 13, 2012
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Today’s Topics
 Discuss submitted questions
 Other tips
 Q&A
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Discussion Topics
1. Proposed settlement for cost-based SLP services
o Need provider-specific details in order to research further
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Discussion Topics
2. 2011 year-end review rate letters:
– Proposed at 0.71% and 0.36%; tentative settlements reflect 0.50% and
0.57%
• Initially: 14-day lag for pass-through payments
• Based on information we received about how NGS calculated
lag-time, we changed the lag to 17 days
• We can still adjust days if lag-time calculation was inconsistent
between prior years
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Discussion Topics
3. CGS requested “Exhibit 1 Coinsurance Bad Debt” schedules
for 2010 and 2011; these were already submitted with the
ECRS files
4. Requests to resubmit ECRS files- please explain
• Most prior files were transferred to CGS from the prior
contractor
• In some cases, we could not locate these documents in the
transferred files
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Discussion Topics
5. Policies for pass-through payments and issuance of lumpsum adjustments
• For SNFs:
– Pass-through payments determined based on allowable bad debts
calculated during tentative review of cost report: CGS calculates
interim adjustment
– Adjusted rate continues for 6-7 months into the new year; results in
large variances in amounts due reported on the as-filed cost reports
– Lump sum determination supports a more even flow of funds w/ biweekly payments
– CGS uses a $5,000 materiality factor for issuance of lump sum
payment adjustments
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Discussion Topics
5. Policies for pass-through payments and issuance of lumpsum adjustments
• For hospitals:
– At least 2 rate reviews are completed during the year
• 1 based on calculations made during tentative review of filed cost report
• If possible, 1 based on findings from desk review and audit (if performed)
and settled w/ Notice of Program Reimbursement
• Interim payment adjustments are determined during the rate review
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Discussion Topics: #6
Topic
Timeframe for Completion
Cost report acceptance
Within 30 days of receipt
Tentative settlements
Within 60 days of acceptance
NPRs (non-audit units)
Within 1 year of acceptance
NPRs (audit units)
Within 60 days of exit conference
Audit adjustment
During pre-exit conference and/or
completion of desk review
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Discussion Topics
7. No-pay bills
• Providers are required to submit a bill, even though no
benefits may be payable by Medicare
• This allows CMS to keep track of the benefit period
• Must submit no-payment bills for beneficiaries that have
previously received Medicare-covered care and subsequently
dropped to a non-covered level of care but continue to reside
in a Medicare-certified area of the facility
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Discussion Topics
7.
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No-pay bills
TOB 210
Include from-to dates
Submit all days/charges as non-covered (non-covered days
and charges beginning with the date after active care ended)
• Condition code 21
• Patient status: use appropriate code
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Discussion Topics: #8-9
• Key contacts
– PCC: most questions – CSR line is 866.590.6703
• Request escalation as necessary
• Voicemail box for escalated issues: 803.763.4488
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Sheri Thompson: 615.660.5175, [email protected]
Ken McCullough: 615.660.5140, [email protected]
Jennifer Brown: 614.657.0170, [email protected]
Overpayments and A/R adjustments:
– Michelle Tennant (primary): 615.782.4553, [email protected]
– Noelle Weybright (secondary): 615.782.4416,
[email protected]
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Discussion Topics
10. CGS may not have received current mailing addresses for
facilities during J15 implementation – how to rectify?
• CGS sends reminder letter for cost report to address listed in
the National STAR (System for Tracking Audit &
Reimbursement)
• CGS can update if we are notified
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Discussion Topics
11. Proposed lawsuit settlement re: chronic conditions in home
health care, SNF stays, and outpatient therapy
• Lawsuit brought at federal level
• CMS will provide direction to contractors if/when changes in
guidelines are made
• CGS will communicate directly with associations and via
listserv
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Discussion Topics
Other reminders:
• Requests for documentation based on medical review
activities:
• Please respond w/in 30 days
• Include all appropriate records
• Be aware of signature requirements (PIM, chapter 3, section 3.3.2.4)
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Discussion Topics
Other reminders:
• Therapy caps
• Reference CMS MLN Matters article MM8036 and MM7785
• CGS web article: “Therapy Cap Exception”
• Q&As from CGS Ask-the-Contractor Teleconference
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Revised October 23, 2012
© 2012 CGS Administrators, LLC.
Questions?