Signing Your Life Away: Cost Report Certification

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By Jack Ahern, MBA

The recent rework of the cost report by CMS, the CMS 265 – 11, represents a substantial increase in the information to be provided on the CMS 265, but one aspect of the new cost report that very closely mirrors the older version is the officer or administrator certification on part III, of worksheet S. This month I want to review in detail this very important, but often glossed over portion of the cost report. If you have specific cost report questions which you would like addressed in a future article, feel free to contact me directly at jahern@ahernconsulting.com, I am sure your questions will be of interest to many of our readers.

WARNING
The certification section of worksheet S of the cost report, is preceded by a warning, printed in capital letters which reads as follows:

MISREPRESENTATION OR FALSIFICATION OF ANY INFORMATION CONTAINED IN THIS COST REPORT MAY BE PUNISHABLE BY CRIMINAL, CIVIL AND ADMINISTRATIVE ACTION, FINE AND/OR IMPRISONMENT UNDER FEDERAL LAW. FURTHERMORE, IF SERVICES IDENTIFIED IN THIS REPORT WERE PROVIDED OR PROCURED THROUGH THE PAYMENT DIRECTLY OR INDIRECTLY OF A KICKBACK OR WERE OTHERWISE LLEGAL, CRIMINAL, CIVIL AND ADMINISTRATIVE ACTION, FINES, AND/OR IMPRISONMENT MAY RESULT.

During a week long advanced cost report preparation course I took in Cambridge, Mass., some years ago, I recall being told about a large hospital chain that ultimately ran into significant problems regarding its hospital cost report. I was told that for many years a very senior executive, such as the CFO, had signed the cost report, but the year that problems were first discovered, a less senior officer was delegated the duty of signing the cost report. As investigations continued, time did not stand still and so another cost report had to be submitted for the following year. This time an even lower ranking financial manager signed the cost report. Sadly, troubles continued, and a year later, the cost report was submitted without signature. The investigation wrapped up, and serious charges were laid against the senior management of this chain which ultimately plead guilty to 14 felonies, including filing of false cost reports.

Having read this sobering warning, and every signer should take time to read it carefully, the officer or administrator of the dialysis facility is required to certify that the cost report is, to the best of his/her knowledge accurate.

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