Overview

The OIG’s Compliance Program Guidance for Hospitals and for other health care providers clearly identifies the filing of false cost reports as a potential compliance exposure area.

CCI believes that effective compliance programs should include reviews of current and prior year cost report filings, as well as existing reimbursement-related procedures and practices in order to identify potential risks, as well as assess compliance with current and pending regulatory requirements.

CCI’s review of cost report filings is specifically intended to:

• Identify any sizable settlement amounts, noting instances of aggressive rate setting practices;
   
• Assess fiscal intermediary audit adjustments, particularly those of an unusual nature, which may be indicative of overly aggressive cost report filings or inaccurate preparations;
   
• Document recurring and repetitive audit adjustments;
   
• Review reclassifications and adjustments to expenses in an effort to assess compliance with applicable regulations and to ensure that prior year audit adjustments have been appropriately incorporated, and;
   
• Evaluate the procedures for identifying and eliminating unallowable expenses, paying particular attention to travel and entertainment costs, miscellaneous expenses, public relations and advertising costs, charitable and political contributions, etc.