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RHCF Cost Reports Due July 29th

We remind nursing home members that 2018 Medicaid cost reports are due July 29th. Members should ensure that any necessary Health Commerce System (HCS) permissions are in place now for any staff who will file and/or certify the report. The permissions application is available here. The Dear Administrator Letter (DAL) announcing the posting and a scan of the new page that was added to the report are available here. Members should make every effort to file an accurate and timely cost report to avoid a detrimental impact on their home's Nursing Home Quality Initiative (NHQI) score.

In addition, Executive Order (EO) #38 Financial Disclosure Reports are due on the Medicaid cost report due date. EO #38 requires covered providers who receive State funds or State-authorized payments to submit a Disclosure Form with information on administrative expenses and executive compensation no later than 180 days after the close of their covered reporting period or the date on which their Medicaid cost report is due, whichever is later.

Last fall, a Court of Appeals opinion annulled the “soft cap” portion of the EO #38 regulations, which caps executive compensation paid from all funding sources, but upheld the “hard cap,” which limits executive compensation paid from State funds and State-authorized payments (more information available here). The Court also upheld the cap on administrative costs, which limits those expenses paid with State funds and State-authorized payments incurred in connection with management overhead but which are not attributable directly to provision of program services.

We continue to seek guidance on whether the State will revise the format or timing of the required reporting in light of the ruling, but at this point, no changes to the required reporting have been announced. The EO #38 webpage with filing guidance, forms, and FAQs is here.

LeadingAge NY Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841