On March 1, 2013, the Provider Reimbursement Review Board (PRRB or the Board) issued Alert 9, which notified interested parties that the PRRB has made revisions to its Rules and updated its Model Forms. Medicare providers that file appeals with the PRRB should review the revisions to ensure that their appeal filings and other documents comply with the Board’s revised requirements.
The rule revisions were effective on March 1, 2013, and apply to appeals pending as of, or filed on or after, March 1, 2013. The revised rules supersede the previously issued rules, which were last revised on July 1, 2009.
The rule revisions include the following:
The Board also made revisions to its Model Forms, and requested that providers begin using the revised Model Forms as soon as possible. Providers should carefully review the revised Model Forms, because some of the Model Forms include requirements and instructions that are not set forth in the Rules.
PRRB Alert 9, the revised Rules, and the revised Model Forms can be accessed here: http://cms.gov/Regulations-and-Guidance/Review-Boards/PRRBReview/PRRB_Alerts.html.
For the past several years, the Centers for Medicare & Medicaid Services (CMS) has been recalculating the Medicare fraction (also known as the Supplemental Security Income (SSI) fraction) that is used to determine whether a hospital is entitled to receive Disproportionate Share Hospital (DSH) payments and, if so, the amount of those payments. It appears that CMS has completed these recalculations for many hospitals for certain cost reporting periods. Thus, it is likely that the Intermediaries and Medicare Administrative Contractors will be issuing numerous NPRs and Revised NPRs, with recalculated Medicare fractions and DSH payments, in the near future. In filing appeals, providers need to make sure that their appeal filings are in compliance with the Board’s revised requirements to ensure that their appeals will be accepted.
Legal News Alert is part of our ongoing commitment to providing up-to-the-minute information about pressing concerns or industry issues affecting our health care clients and colleagues. If you have any questions about this Alert or would like to discuss this topic further, please contact your Foley attorney or any of the following individuals:
Jeffrey R. Bates
Los Angeles, California
Lawrence W. Vernaglia
Donald H. Romano
Chris E. Rossman