1. Al Josephs Hillcrest Health System1 Things to Look for in Monitoring the Cost Report Process HCCA’s 2000 Compliance Institute September 25, 2000 New Orleans, Louisiana

2. Al Josephs Hillcrest Health System2 Introduction Compliance issues related to the external reporting of organizational information often associated with financial reporting  Contact information:  ajosephs@hillcrest.net  254-202-8620

3. Al Josephs Hillcrest Health System3 Samples of External Reporting Provider Cost Report Reimbursement Questionnaire HCFA-339 (PCCRQ) Cost Report HCFA 2552 Bond Issue Covenants AHA Annual Survey

4. Al Josephs Hillcrest Health System4 Provider Cost Report Reimbursement Questionnaire HCFA-339 (PCCRQ) Document required to be submitted with the Cost Report Purpose: To assist in the preparation of an acceptable cost report and to minimize the need for direct contact between the provider and the intermediary

5. Al Josephs Hillcrest Health System5 PCCRQ HCFA 339 Categories of Questions  Organization and Operations  Financial Data  Insurance  Deferred Compensation  Educational Activities  Non-paid Workers

6. Al Josephs Hillcrest Health System6 PCCRQ HCFA 339 Categories of Questions--cont’d  Purchased services  Provider based physicians  Bad debts  Bed complement  Owner/Management comp.  Wage related cost

7. Al Josephs Hillcrest Health System7 PCCRQ HCFA 339 Assignment of Responsibility  Human Resources  Senior Management  Finance/Reimbursement  Patient Accounting

8. Al Josephs Hillcrest Health System8 PCCRQ HCFA 339 Prioritize your approach (based upon identified risk within your organization): 1. Provider based physicians 2. Purchased services 3. Bad debts 4. Wage/Compensation issues

9. Al Josephs Hillcrest Health System9 PCCRQ HCFA 339 Provider Based Physicians Review Plan  Identify related questions  Compile related rules and regulations  Review all agreements  Review related policies and procedures

10. Al Josephs Hillcrest Health System10 Cost Report HCFA- 2552 Document for reporting the cost of health care services provided to Medicare beneficiaries Purpose: To supply information required to determine annual program reimbursement and provide a data base to aid in the management of Federal programs

11. Al Josephs Hillcrest Health System11 Cost Report HCFA-2552 Representation & Certification Statement See Handout

12. Al Josephs Hillcrest Health System12 Cost Report HCFA-2552 Table of Contents 100 Depreciation 200 Interest Expense 300 Bad Debts, Charity, and Courtesy Allowances 400 Cost of Educational Activities 500 Research Costs 600 Grants, Gifts, and Income From Endowments

13. Al Josephs Hillcrest Health System13 Cost Report HCFA-2552 Table of Contents--cont’d 700 Value of Services of Nonpaid Workers 800 Purchase Discounts and Allowances and Refunds of Expenses 900 Compensation of Owners 1000 Cost to Related Organizations 1200 Return on Equity Capital of Proprietary Providers

14. Al Josephs Hillcrest Health System14 Cost Report HCFA-2552 Table of Contents--cont’d 1400 Reasonable Cost of Therapy and Other Services Furnished by Outside Suppliers 2100 Costs Related to Patient Care 2200 Determination of Cost of Services to Beneficiaries 2300 Adequate Cost Data and Cost Finding

15. Al Josephs Hillcrest Health System15 Cost Report HCFA-2552 Table of Contents--cont’d 2400 Payment to Providers Limitations on Coverage of Costs Under Medicare and Notice of Schedule of Limits on Provider Costs 2600 Lower of Cost or Charges 2700 ESRD Services and Supplies 2800 Prospective Payments

16. Al Josephs Hillcrest Health System16 Cost Report HCFA-2552 Table of Contents--cont’d 2900 Provider Payment Determination And Appeals Procedures 3000 NON-PPS Hospitals and Distinct Part Units

17. Al Josephs Hillcrest Health System17 Cost Report HCFA-2552 Prioritize your approach (based on identified risk within your organization): 1. Cost Finding Statistics Square feet Pounds of laundry Hours of service Meals served

18. Al Josephs Hillcrest Health System18 Cost Report HCFA-2552 Prioritize your approach:--cont’d 2. Non-Reimbursable Cost 3. Non-Reimbursable Cost Centers 4. Bad Debt, Charity, and Courtesy Allowance 5. Education

19. Al Josephs Hillcrest Health System19 Cost Report HCFA-2552 Bad Debt, Charity, and Courtesy Allowance Review Plan  Evaluation of policy and procedures  Review of any FI audit adjustments  Interviews with staff  Flow chart of process

20. Al Josephs Hillcrest Health System20 Other External Reporting Bond Covenants AHA Annual Survey IRS Form 990 Tax-exempt organizations

21. Al Josephs Hillcrest Health System21 Conclusion Responsibility for completion of these documents has traditionally been assigned to the finance/reimbursement functions in most organizations. The compliance professional will have little to add to the “number crunching” components of the process.

22. Al Josephs Hillcrest Health System22 Conclusion The skills of the compliance professional are expected to be focused on the related rules and regulations, instructions, and the evaluation, testing, and monitoring of the many processes that bring the required information together for use in external reporting.