December 09, 2015
CT Association of Residential Care Home
By Stephen Bernier, Manager, Advisory Services
It's that time of year again. The time when the days begin to get shorter and the greatly awaited rate computation reports start arriving in the mail. So what do you do with these wonderful reports after quickly glancing to see what your new rate is? Go right to the budget and try and figure out how to make ends meet? At Marcum LLP, we strongly suggest reviewing these reports in great detail. There is plenty that can be learned by performing an in depth rate computation report review, and there's always the possibility of coming across an error or two.
The first and most important step when to stake when a rate computation report arrives is to immediately file a ten-day blanket appeal letter. Pursuant to Section 17b-238(b) of the Connecticut General Statutes, you only have ten days from the date of the letter (not necessarily ten days from when you personally receive the letter) to file a request for an administrative rate rehearing. This does not lock you into any mandatory obligations, but simply grants you an additional ninety days to review the rate calculations, and if appropriate, file a detailed letter of all items of aggrievement. Should you find that there are no errors in the rate calculation and you agree with all adjustments made during the desk review and property only reviews, then you simply do not respond within the next ninety days and your appeal is deemed to be withdrawn.
Once your blanket appeal letter is filed, it's time to sit down and review the report and all calculations. Some of the main areas that should be considered, but not limited to, during this review are as follows:
- Expenses per the as-filed Medicaid Annual Report for Long Term Care Facility
- Indirect efficiency and limitation calculations
- Administrator and related party (if applicable) salary caps
- Desk review adjustments
- Property only adjustments
- Not for profit providers - the implementation of fair rent vs. interest and depreciation calculation
Now that you have reviewed the rate computation report in detail, you can make a decision whether or not to move forward with the detailing listing or simply let your ninety day window expire. Should you find material errors and wish to move forward with the appeal, you want to be certain to make all your items of aggrievement very clear to the Department of Social Services (DSS). This letter should include how DSS proposed to handle aggrieved items, why you are not in agreement with said items, and respectfully requesting how this should be handled.
If you have any questions while performing a rate review, want a second opinion, or have any questions regarding the process, please contact Matthew Bavolack, National Healthcare Industry Group Leader or Stephen Bernier, Manager, Advisory Services.