[PROVIDER] is required to submit various cost reports to federal and state governments in connection with its operation and to receive payment. Such reports will be prepared as accurately as possible and in conformity with applicable law and regulations. If errors are discovered, billing personnel shall contact an immediate supervisor promptly for advice concerning how to correct the error(s) and notify the appropriate payor.
Providers may wish to include the following suggested elements in their corporate compliance policy:
Cost Reporting Guidelines: in the preparation of cost reports or the compilation of information to be sent to outside parties to prepare cost reposts on [PROVIDER’S] behalf, all employees involved in the preparation shall ensure that:
- Costs are consistent with prudent buyer principle rules, and reasonably related to patient care;
- Information provided for or used in the cost report is adequately supported by documentation;
- Non-allowable costs are properly identified and removed;
- Costs are reported in the appropriate cost categories;
- Statistics are based on reliable information;
- Related parties are identified and their services treated in accordance with program rules; and
- Costs claimed in non-conformity with program rules, as interpreted by the Medicare or Medicaid program or the fiscal intermediary (FI), either are disclosed in a letter accompanying the cost report or are included in protested amounts.
Reporting False Cost Reporting Practices: If an employee or agent who has any reason to believe that anyone (including the employee himself or herself) is engaging in questionable or false cost reporting or is engaged in questionable internal accounting practices shall immediately report the practice to his or her immediate supervisor, the [compliance hotline, anonymous drop box, post office box, etc.], or the compliance officer or any of the officers designated to receive such report verbally or in writing. Employees or agents who report a suspected cost reporting or accounting irregularities in good faith shall not be retaliated against or subject to adverse action.
Failure to act when an employee has knowledge that someone is engaged in questionable cost reporting or accounting irregularities shall be considered a breach of that employee’s or agent’s responsibilities and shall subject the employee to disciplinary action by [PROVIDER], including possible termination of employment or of their contractual relationship with [PROVIDER].