Welcome to this entry into my Reimbursement Blog! If you are a new reader, I invite you to take a moment and subscribe to the blog through the link at the bottom of this page.
Throughout the history of the Medicare cost report, you could always count on a hospital receiving another Notice of Program Reimbursement (“NPR”), or audited cost report, almost every year. This was the case until 2010 when The Center’s for Medicare and Medicaid Services (“CMS”) placed a hold on all cost reports that were potentially impacted by the SSI Ratio; therefore, all hospital cost reports which had DSH reimbursement were placed in a timeout for an indefinite period of time. In the last year, CMS has begun instructing it’s MAC’s to begin the process to issuing several years of belated NPR’s.
While none of this is probably news to anyone in the field, what is important is to remember that the issuance of the NPR starts the clock ticking on cost report reopening (3 years) and PRRB appeal (180 days) deadlines. Prior to the CMS delays, most major hospitals had a process in place to ensure that every new NPR was appealed in a timely fashion and that the reopening deadlines were at least noted. The hospital’s appeal of every new NPR held the hospital appeal rights “open” for additional time and allowed group appeals issues to be added and transferred.
My concern at this time is that several years of no NPR’s may have caused hospital personnel or consultants to get off their appeal and reopening game so to speak and to potentially miss deadlines as the newly issued NPR’s pile up quickly. I recently became aware of one such case for a FYE 2007 NPR issued last fall. From January 1, 2013 through 2015 should be a renaissance period for the PRRB Appeal, and to a lessor extent the Medicare reopening, due to the large number of NPR’s that will be issued during this time period. Hospital personnel, Attorneys and Consultants that specialize in appeals and have had little appeal work to do in recent years should be swamped with appeal requests and position papers!
If you have let the years passing fog your memory regarding PRRB procedures, deadlines, etc, now is the time to act! You may have an NPR date related clock ticking right now that you were not even aware of! I encourage you to check any NPR’s and document those dates, so not to miss an important one.
I hope this and all future blog entries help you identify the most important reimbursement issues and new developments in the field for you. If we can be of help with the above or other issues, please let me know!