Cost Report Reopenings for JM

Palmetto GBA updated its cost report reopening guidelines for Jurisdiction M and is presenting the following information as official notification of changes and clarifications to existing guidelines. 

Cost Report Reopenings Involving Authorized Agents and Consultants 

If a Provider engages an authorized third-party agent or consultant (not employed by the Provider) to act in any way on behalf of the Provider in a requested reopening, the Provider must submit written authorization for the MAC to communicate with the third party, along with the reopening request. This authorization is needed even if the Provider engaged the same agent or consultant on the As-Filed Cost Report, as the Medicare Administrative Contractor (MAC) cannot assume that an agent or consultant still has authority to act for the Provider past the settlement of an As-Filed Cost Report.

Materiality Threshold 

For cost report reopenings, the reimbursement impact at the time of the request must equal or exceed $10,000 and will be applied to any reopening request received. 

If you have questions about the reopening process or if your issue would qualify for a reopening, please contact JMaudit.reopening@palmettgba.com.

Documentation

All supporting documentation should be sent with the reopening request and must include the reimbursement impact of the reopening. The reimbursement impact should be itemized for each requested reopening issue. Providers must also document why the information or issue is new and material to the facility. If applicable, a provider must include a statement which supports the reason why the information was not available at the time when the As-Filed Cost Report was submitted. 

The preferred file format for sending supporting schedules/listings submitted with the reopening request is Excel.

Palmetto GBA’s determination to grant the reopening request will include an evaluation of all of the above factors. Palmetto GBA will contact the provider within 90 days of the specific reopening request. 

Reopening Process

Once the reopening review is started a Notice of Reopening to grant a reopening or Notice of Denial will be sent to the provider. If a reopening is granted, the review steps will be determined and it is possible additional information will be requested from the provider for sampling items such as additional bad debts or DSH days.

Bad Debt Reopening: When requesting a reopening for additional bad debts, the additional bad debts should be separately identified on a bad debt log or logs with all required bad debt information. 

Additional Eligible DSH days: If the provider is requesting additional DSH days, they should send a listing of only the additional days identified. If the original DSH listing was not sent with the as filed cost report or not provided during the desk review, it should be sent as a separate listing from the additional requested days. The original DSH listing should reconcile to the settled cost report. 

SSI Realignments: Providers should send all requests for SSI realignments to the JMaudit.reopening@palmettgba.com reopening mailbox for further review.

Electronic Submission Process

Please submit your cost report reopening request and supporting documentation in a secure electronic format through the JJ reopening mailbox at JMaudit.reopening@palmettogba.com,

U.S. Mail and Courier Addresses

If you are unable to securely transmit your reopening request electronically, please send via mail to: