Top Provider Questions – Cost Report Reopening
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- Why can't I send my reopening request to the auditor who completed the audit?
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We ask that reopening requests be sent to the staff member responsible for coordinating the reopening area, as this ensures that the reopening requests are tracked and assigned to the appropriate staff in a timely manner. Once your reopening request has been received, the staff member will contact you to confirm receipt of your request.
Reopening correspondence should be sent via e-mail to J15.CR.reopening@cgsadmin.com. If situations arise where correspondence cannot be sent electronically, please submit requests to:
Judith Cummings, Manager
J15 Audit and Reimbursement
Attn: Cost Report Reopenings
26 Century Blvd, Suite ST610
Nashville, TN 37214Reviewed 09/30/2021
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- How long do I have to request a reopening?
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Per the Provider Reimbursement Manual 15-1, section 2931.1, a reopening made upon request is timely only if the request to reopen is received by CMS, the contractor, or reviewing entity, as appropriate, no later than three years after the date of the determination or decision that is the subject of the requested reopening.
Reviewed 09/30/2021
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- Is a reopening a final determination that would allow me to request another reopening?
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Per the Provider Reimbursement Manual 15-1, § 2931.1G, "the time period during which a determination or decision may be reopened under the 3 year rule commences on the date of the notice of amount of program reimbursement containing the intermediary's determination, or the date of the notice of intermediary hearing decision, PRRB decision or Secretary's decision, as the case may be."
If a cost report has already been previously reopened, the amended notice of program reimbursement (NOPR) date would be used as the start of the three year time period only if the reason for reopening the second time is for the same issues as was previously reopened. However, if the reopening is for new issues, the start of the three years would begin the date of the original notice of program reimbursement. For example, if a cost report was finalized on January 2, 2014, and it was reopened to incorporate finalized home office costs and an amended NOPR was issued on February 20, 2014, the three year time period would begin on February 20, 2014, to request a reopening related to an error in the calculation of the amended home office expenses. However, if the provider noticed an error on the finalized Medicare Cost Report (MCR) such as a statistic not properly stated, the three year time period would begin on January 2, 2014, as the issue was not related to the initial reopening.
Reviewed 09/30/2021
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- Why can some reopenings be completed after the time limits have expired?
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The Medicare Administrative Contractor (MAC) must issue a notice of reopening, or the provider must submit a written request for reopening, with adequate support, within three years of the date of the original Notice of Program Reimbursement (NOPR). As long as the notice of reopening has been issued, or a request has been received in writing within the three year timeframe, an amended NOPR can be issued after the three year time frame period has expired.
Reviewed 09/30/2021
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