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Submission of a Medicare Cost Report Reopening Request

In accordance with CMS policy (42 Code of Federal Regulations 405.1885 and CMS Internet-Only Manual Publication 15-1, The Provider Reimbursement Manual, Section 2931), a provider may request a reopening of their Medicare cost report. This request can be made once a final settlement has been issued as notified via NPR. The request is to be made to the MAC who has jurisdiction at the time of the request. The MAC will review the request to determine whether or not to reopen the cost report.

Reopening requests can be sent to National Government Services utilizing three different options listed in order of preference: email, NGSConnex and mail. If requesting by email, a provider may request confirmation of receipt and NGS will respond via email once received. Email attachments including PHI/PII must be encrypted and the password shared separately. NGSConnex is a secure portal and the encryption of files containing PHI/PII is not necessary when uploading to the portal. Once successfully submitted through NGSConnex you will receive an automated response confirming the successful submission.

It is advised to submit through mail only as a last resort when email or NGSConnex is not a viable option. Please do not submit the same request through more than one option. Duplicates will lead to delays and/or processing complications.

The address options are listed below:

Email

NGSConnex Portal

Mail

  • Regular Mail:

    National Government Services, Inc.
    Attn: Cost Report Reopenings
    P.O. Box 9731
    Portland, ME 04104
  • FEDEX or Courier ONLY:

    National Government Services, Inc.
    Attn: Cost Report Reopenings
    2 Gannett Drive
    South Portland, ME 04106

A reopening request should include the following information either in a cover letter or in the body of an email:

  • Medicare provider name, six-digit provider number and cost report fiscal year end.
  • Clearly specify the issue requested to be reopened, the reason, and why it is believed to meet the conditions to qualify for a reopening.
  • Include the estimated reimbursement dollar impact.
  • Include the specific requested adjustments to the cost report (i.e. worksheet, line, column and amount for each adjustment.

The request should include supporting documentation where applicable. It is not necessary to supply all supporting documentation that would be needed for audit testing. As an example, a request to reopen for additional Medicaid Eligible days as a result of new data should include a listing of those days, however the source documentation for each claim such as the UB is not necessary. An NGS Auditor will request for the additional documentation if necessary.

The request should include a copy of the previous NPR letter for which the reopening is being requested from.

The request should be made by the provider directly. If the provider authorizes NGS to work directly with a third party on this request please specify the contact information in the letter.

  • If a reopening request is made directly by a third party, it must be endorsed in writing by the provider. The request would need to include a letter on the provider’s letterhead signed by an authorized contact. The reopening request will not be considered valid until endorsed by the provider.

To qualify as a reopening, the following conditions apply:

  • The request must be received within three years of the notice of intermediary hearing decision, determination of final settlement (i.e. date of NPR letter), or Provider Reimbursement Review Board decision.
  • There must be new and material evidence submitted, or a clear and obvious error was made or the previous determination is found to be inconsistent with the law, regulations and rulings or general instructions. The reopening request should include an explanation as to why the provider believes these conditions are met.
  • It is the contractor’s discretion on whether or not reopen the cost report as requested by the provider. The decision to reopen is made on a case by case basis. Below includes additional information that NGS utilizes in the evaluation process.
    • To be a clear and obvious error, it has to be conclusive and easily verifiable. This would be based on either the information supplied in the request and/or based on the information that NGS has readily available. Common examples relate to errors the contractor made in settling the cost report (i.e. mathematical or data entry error). Generally, issues that require further audit testing by the contractor and were not claimed as part of a cost report filing do not fall into this criteria.
    • NGS will determine if it meets the criteria of being material as part of the evaluation process.
    • To be new evidence, there must be evidence that the data is new. This means the data was not available at the time when the provider filed the cost report, nor at the time of a subsequent due date in which there was an opportunity to amend the cost report.
Submitting a Cost Report Reopening
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