Did you know that CMS has a Proposed Change to the Home Health Cost Report?

And that it could be effective for cost reports being prepared for CY2019?

Chances are that your internal records (the Chart of Accounts, your time-keeping, etc…) and your EMR are likely not ready for this change, and as of right now, there is NO postponement/extension of the current June 1st deadline for all Medicare Cost Reports to be submitted for CY2019. 

But, there is still time to make your voice heard!

An overview of the changes includes:


  • Change from 1728-94 which has been used for decades to

  • CMS Form 1728-19, w/all kind of big changes/additional detail requirements

  • Was originally proposed back in April 16, 2019 Federal Register

  • w/a follow-up in the Federal Register dated Feb 24, 2020

  • Comment period ends tomorrow – you should consider submitting a comment (see below)

  • Proposed to be applicable to all cost reporting periods beginning on/after Jan 1, 2019, meaning

  • The CY2019 CRs that everyone should be working on, could be subject to this change!

  • Significantly more detail from a visits, costs and hours worked perspective, with:

  • All Skilled Nursing information (visits, costs, time worked, etc…) being broken down by: RNs and LPNs

  • All Physical Therapy information (visits, costs, time worked, etc…) being broken down by: PTs and PTAs

  • All Occupational Therapists information (visits, costs, time worked, etc…) being broken down by: OTs and COTAs

  • Let alone the changes (increases in detail) to the various Cost Centers (over and above those noted above)

Here is a link to be able to view the Proposed Cost Report and CMS’ additional information therein:

I’d recommend everyone go in and at least comment here: https://www.regulations.gov/docket?D=CMS-2019-0065

request that the 1728-19 be delayed until cost reporting periods beginning on/after March 1, 2020

So the episodic information of W/S S-3, Pt IV, would not be forced to combine the episodic information for the 60-day PPS episodes that started in late 2019 and ended in Jan & Feb 2020 with the episodic info for the PDGM episodes that began and ended in Jan & Feb 2020.

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