Low/No Utilization Medicare Cost Reports

"No Medicare Utilization" Cost Report Criteria

A provider that has not furnished any covered services to Medicare beneficiaries during the entire cost reporting period need not file a full cost report to comply with program cost reporting requirements. The provider must submit to Noridian a statement, signed by an authorized provider official, which identifies the reporting period to which the statement applies and states that (1) no covered services were furnished during the reporting period and (2) no claims for Medicare reimbursement will be filed for this reporting period. This statement must be accompanied by a completed certification page of the applicable cost report forms. The proper form and signed statement must be submitted within 150 days following the close of the reporting period.

"Low Medicare Utilization" Cost Report Criteria

The contractor may authorize less than a full cost report where a provider has had low utilization of covered services by Medicare beneficiaries in a reporting period and received correspondingly low interim reimbursement payments which, in the aggregate, appear to justify making a final settlement for that period based on less than a normally required full cost report. Effective for all cost reports filed on or after June 19, 2020, in order to file a low utilization cost report, the provider must meet one of the following thresholds:

Criteria Hospital Threshold SNF Threshold RHC/FQHC Threshold
Total Reimbursement $200,000 $200,000 $50,000


Note 1: Total Reimbursement is the sum of the current interim payments on the PS&R, total bi-weekly payments (including Periodic Interim Payments) and total lump sum adjustments.

Note 2: The above thresholds will be applied to the cost report being submitted for the entire provider complex (family). This means if a hospital cost report is being submitted with a provider-based FQHC, the Low Medicare Utilization threshold used will be the $200,000 hospital threshold amount; it will not be $250,000 (which would be the hospital $200,000 threshold plus the FQHC $50,000 threshold).

Providers other than those shown above should inquire with Noridian for the requirements to file a low utilization cost report.

The net reimbursement threshold amount is based on a 12-month filing period. Providers with a short period cost report need to annualize their net reimbursement to compare to the above thresholds.

Providers filing low utilization may not claim Medicare bad debts. If a Provider is claiming Medicare bad debts, they must file a full cost report.

The following forms are required when filing a Low Utilization Medicare Cost Report:

  • Signed Officer Certification Sheet with applicable "S" Worksheets,
  • Balance Sheet
  • Income and Expense Statement (the Worksheet G Series may be submitted to satisfy the Balance Sheet and Income and Expense Statement requirements), and
  • Various worksheets based on provider type:

Hospital filing Form CMS 2552-10

  • Worksheet S-2
  • Worksheet S-3
  • Worksheet E Series

Skilled Nursing Facilities filing Form CMS 2540-10

  • Worksheet S-3
  • Worksheet E Series

FQHC and RHC Facilities filing Form CMS-222-92 and 224-14

  • Worksheet S Part I, II and III
  • Worksheet C Part I and II

The Provider must submit the forms and data under this alternative procedure within the same time period required for full cost reports. If it is determined at a later date that a cost report does not meet the criteria for a low or no utilization cost report, or if the contractor determines that a full cost report is necessary to serve the best interest of the program, a full cost report will be required.


Last Updated Mon, 19 Dec 2022 16:24:40 +0000