In January, CMS issued a MLN Matters newsletter reviewing the new electronic system for Provider Reimbursement Review Board (PRRB) Medicare cost report appeals. The electronic system, referred to as OH CDMS (Office of Hearings Case and Document Management System), is a web-based portal that allows providers to submit all necessary appeals documents electronically.
This portal gives providers constant access to their appeal while also allowing the Board to send outgoing correspondence in the hopes to manage appeals in a more timely manner. Using the portal also alleviates the requirement for hospitals to notify their Medicare Administrative Contractor (MAC) since the provider’s MAC is automatically notified when the provider submits the appeal through the portal. Hospital providers can access the OH CDMS portal through the CMS Enterprise Portal and could be used to submit appeal packages. More information on OH CDMS can be found on the CMS website, including user manuals and FAQs.
The use of OH CDMS was first introduced as a part of Alert 15 which contained the PRRB rule revisions that became effective August 29, 2018. The complete listing of rules can be found here, however, here are the revision highlights as listed in Alert 15:
Introduce the Office of Hearings Case and Document Management System (“OHCDMS”) and implement its use into the rules;
Require the transfer of issues from individual appeals to a common issue related party group (CIRP) appeals (if applicable) prior to the submission of the preliminary position paper or proposed joint scheduling order in order to comply with the related party regulations and narrow the issues briefed in the briefing;
Require the filing of the full preliminary position paper to both the opposing party and the Board (currently the preliminary position paper is only filed on the opposing party with only a cover letter to the Board);
Eliminate the requirement for a final position paper, making its submission optional and used to narrow the issues prior to hearing (applicable only for new appeals filed after the issuance of the Rules);
Eliminate the requirement of the post hearing brief, making its submission optional and subject to the Board’s request
Provide an additional reinstatement option, where providers can file an appeal to protect their appeal rights, but withdraw it immediately to handle through a reopening with the MAC. Those cases, if not resolved by the parties, would have the option of being reinstated by the Board
Last but not least, this information is only relevant IF a provider meets the requirements to file an appeal. As a reminder, the criteria to be eligible to file a Medicare cost report appeal with the PRRB is as follows:
Provider must be dissatisfied with a final determination or Notice of Program Reimbursement (NPR) by CMS or the provider’s MAC
Final determinations could be:
Exception decisions
Quality reporting reduction decisions
Provider reimbursement issues addressed through the federal register
Provider must show that the impact to their facility is greater than or equal to $10,000 for an individual appeal or $50,000 if it is a group appeal
Provider must file their request for review within 180 days of the final determination or NPR date
We will keep you apprised of future PRRB updates as they become available, but if you have any questions or concerns in the meantime, please don’t hesitate to leave a comment below or send an email to appeals@southwestconsulting.net.
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