Cost Report Reopening Request - JE Part A
Cost Report Reopening Request
A request for a cost report final determination reopening may be honored by Noridian if: 1) new and material evidence has been submitted, or 2) a clear and obvious error was made, or 3) the determination is found to be inconsistent with the law, regulations and rulings, or general instructions.
For purposes of reviewing a request for a reopening, Noridian is defining "new and material evidence" to include any evidence that:
- was not readily available or known to the person or entity requesting/initiating the reopening at the time of the initial filing of the cost report; and
- may result in a conclusion different from that reached in the initial filing of the cost report.
- Noridian uses a cumulative reimbursement materiality threshold of $10,000 as part of their reopening approval/denial criteria.
Noridian defines a "clear and obvious error" as an error that occurred to the initial determination or decision based on incorrect evidence on file on which the determination or decision was based or any evidence of record anywhere in the contractor's Medicare file or in CMS files at the time such initial determination or decision was made.
When submitting a request for a cost report reopening, the request must be in writing from the provider signed by an official of the provider and be received by Noridian no later than 3 years after the date of the initial determination or decision that is the subject of the requested reopening. A request may be submitted by a party on behalf of the provider. If a request is submitted by another party on behalf of a provider, it must include a Letter of Representation (on provider letterhead) signed by an official of the provider. The Letter of Representation must indicate that the designation is applicable to the specific cost report reopening request.
The reopening request should:
- Identify the applicable cost reporting period(s).
- Identify the specific issue(s) for which the reopening is being requested. (ex. Traditional Bad Debts vs simply stating Medicare Bad Debts)
- Identify the reimbursement dollar impact for each issue and meet the cumulative Noridian materiality threshold of $10,000.
- Include documentation in sufficient detail to support the request.
- Requests should be submitted by email to: costreportreopening@noridian.com Cost Report Reopening requests submitted to any other email address will not be considered and will be returned to the Sender. Proper submission of the Cost Report Reopening request using the designated email address will ensure timely processing of the Cost Report reopening request.
A timely-filed provider reopening request will be examined carefully, in accordance with the above regulations, in order to ascertain whether sufficient evidence exists for reopening. Based upon this review, Noridian then has the discretion to either reopen the cost report or deny the request. It is important to note that Noridian, as a contractor, has a great deal of discretion in these matters. It should also be stressed that Noridian will not summarily reject a request for reopening but will provide adequate rationale for the denial. Providers should note that a determination or decision to reopen or not to reopen a determination or decision is not a final determination or decision and is not subject to further administrative review or judicial review.
Matters relating to cost report reopenings should be referred to the audit manager as listed on the Contact Noridian Management webpage.
Social Security Income (SSI) Realignment
An SSI Realignment is a realignment of the hospital’s SSI Ratio related to the provider’s cost reporting period rather than the federal fiscal year. An SSI Ratio is the ratio of days for patients entitled to Medicare Part A attributable to SSI recipients. A written request for a realignment must be submitted to the MAC by the provider for the MAC to then submit the request to CMS. A request may be submitted by a party on behalf of the provider. If a request is submitted by another party on behalf of a provider, it must include a Letter of Representation (on provider letterhead) signed by an official of the provider. The Letter of Representation must indicate that the designation is applicable to the specific SSI Realignment request.
Written Request Requirements:
- Hospital Name
- Provider Number
- Cost Reporting period end date
- Submitted by email to: costreportreopening@noridian.com
This realignment exception will be performed once per hospital per cost reporting period. There is no statute of limitations on when an SSI Realignment can be submitted as long as one has not already been submitted previously for the same cost reporting period. The resulting percentage will then become the hospital’s official Medicare Part A, or SSI percentage for that cost reporting period.
Matters relating to SSI Realignments should be referred to the audit manager as listed on the Contact Noridian Management webpage.
