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Nursing Home Medicaid Cost Reports Due Aug. 19th

(July 16, 2024) The Department of Health (DOH) posted the 2023 Nursing Home Cost Report software on the Health Commerce System (HCS) on June 18th. The due date for both the report as well as the operator and Certified Public Accountant (CPA) certifications is Aug. 19th. Homes with related parties must send the related party audited financials to nfrates@health.ny.gov for the cost report submission to be deemed complete.

In the Dear Administrator Letter (DAL), available here, DOH points to some submission resources posted on the HCS while reminding that the use of third-party cost report software is NOT acceptable and may cause errors. If the cost report does not load correctly, it will be deemed unsubmitted by DOH, and the provider may be subject to penalty. Because DOH is reticent to entertain extension requests, we urge members, especially those with new Administrators or financial staff, to ensure that they have the necessary HCS permissions in place well in advance of the due date to allow for the timely submission and certification of the report.

Complete and accurate cost reports are always important for the correct calculation of the capital component of the Medicaid rate, which has updated annually based on a two-year lag. While cost report data has not been used to develop the operating component of the Medicaid rate since statewide pricing was implemented, given recent discussions of potential rebasing and/or methodology updates, members should ensure precision throughout the report given the possibility that the reported data may impact operating rates in the future. In addition, we urge members to provide complete and correct data on Schedule P (Staff Turnover), as it may impact eligibility for Advanced Training Initiative (ATI) funding.

When completing the report, members should also keep minimum spending requirements in mind and verify that costs are assigned to the appropriate cost centers. Although legislation enacted last year reduces the likelihood of penalties for homes that use low rates of contract nursing staff, the requirements that nursing homes spend at least 70 percent of revenue on direct care and at least 40 percent on resident-facing staff remain in effect. We expect that the vast majority of members easily met the 70 and 40 percent thresholds in 2023, especially since capital reimbursement is now excluded from revenue. Report submission and HCS access questions should be directed to RHCF-HCS@health.ny.gov with “RHCF Submission” or “HCS Access” in the subject line.

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