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Consolidated Appropriations Act Section 131: Hospitals Have Until November 18 to Submit Disputes to Cost Reporting Data Related to Teaching Adjustments

Posted on November 8, 2022 in Health Law News

Published by: Hall Render

If your organization is a teaching hospital that disputes data in the CMS Hospital Cost Report Information System (“HCRIS”) file in connection with Section 131 of the Consolidated Appropriations Act (“CAA”), you have a deadline of November 18, 2022, to submit information to your Medicare Administrative Contractors (“MACs”). The official CMS posting is available here.

Section 131 of the CAA created new opportunities for some teaching hospitals with disadvantageous PRAs and/or FTE caps to potentially get the opportunity to reset some numbers. View Hall Render’s prior article here to see our full discussion of the new rules.

With little fanfare, CMS made this notification available on its website, reportedly on November 3. In it, CMS establishes a deadline of November 18, 2022, for hospitals that have data they dispute in the hospital’s CMS HCRIS files, for cost report years that are NOT REOPENABLE at this time.

So, if you have reviewed your HCRIS data and dispute data present in the CMS HCRIS file for a cost reporting year that is not reopenable, be advised that this deadline has been established and significant submissions to the MACs may be needed by November 18, 2022. Please see the CMS notification linked above for the full details.

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Hall Render articles are intended for informational purposes only. For ethical reasons, Hall Render attorneys cannot—outside of an attorney-client relationship—answer specific questions that would be legal advice.