ohca/cgs meeting november 13, 2012 cgs administrators, llc november 2012 1

OHCA/CGS Meeting

November 13, 2012

CGS Administrators, LLC November 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 serviceso 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 lump-sum 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/ bi-weekly 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 lump-sum 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. 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

– 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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ohca/cgs meeting november 13, 2012 cgs administrators, llc november 2012 1

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