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Medicare Cost Reports are more than a compliance requirement. They are a foundational part of a provider’s reimbursement strategy, influencing both current and future payments. When a cost report issue affects reimbursement, providers may need to consider whether the matter should be handled through a Provider Reimbursement Review Board (PRRB) appeal, a protested item, or a cost report reopening.

In our recent webinar, “Medicare Cost Report Appeals & Reopenings: What You Need to Know,” presented live on May 13, 2026, by Kristin DeGroat, Chief Legal Officer at Besler Holdings, Inc., we reviewed the key rules, filing requirements, and common issues providers should understand to protect reimbursement opportunities.

Why Cost Reports Matter

A Medicare Cost Report is a financial report that identifies the costs and charges related to healthcare treatment activities. These reports directly impact reimbursement today and can also influence future reimbursement calculations.

Because cost reports establish the record that later supports appeals and reopenings, providers should treat them as an important strategic document, not just a year-end filing.

What Is the PRRB?

The PRRB is established under federal statute and serves as the forum for certain Medicare reimbursement disputes. It’s a five-member panel appointed by the Secretary of Health and Human Services and includes provider representatives and at least one CPA.

Generally, the PRRB hears appeals from Medicare providers regarding final determinations.

What Can Be Appealed?

Healthcare providers may appeal several types of final determinations to the PRRB, including:

• Notice of Program Reimbursement (NPR) or Revised NPR
• Failure to issue a timely determination
• Federal Register notices
• Quality Reporting Program payment reduction determinations
• Exception determinations
• Other Medicare Administrative Contractor (MAC) or CMS determinations of total reimbursement

A key point from the webinar: the appeal must involve a true final determination, and the provider must be dissatisfied with that decision.

PRRB Jurisdiction Requirements

To be eligible for PRRB review, an appeal must generally meet three core requirements:

1. Dissatisfaction

The provider must be dissatisfied with the contractor’s or the Secretary’s final determination of program reimbursement.

2. Amount in Controversy

The amount in controversy must meet the statutory threshold:

• $10,000 or more for an individual appeal.
• $50,000 or more for a group appeal.

3. Timeliness

The appeal must be filed within 180 days of receiving the final determination or if the contractor fails to issue a timely determination, 180 days after the expiration of one (1) year from the date the provider filed their cost report.

Meeting these requirements is essential to securing PRRB jurisdiction.

Who Can Appeal to the PRRB?

Appeals are available to Medicare “providers” including:

• Hospitals
• Hospices
• CAHs
• CORFs
• FQHCs
• HHAs
• RHCs
• SNFs
• Renal dialysis facilities
• Other specified entities

The webinar emphasized that PRRB appeal rights are specific and not available to every type of healthcare professional or organization.

Filing Requirements for PRRB Appeals

All appeals must be filed electronically through OH CDMS.

Supporting documentation typically includes:

• The determination being appealed.
• A provider representative letter.
• Amount in controversy calculation.
• Issue statement.
• Adjustments or protested amount documentation.

Providers may file individual or group appeals, depending on the issue and circumstances.

Commonly Appealed Issues

The webinar highlighted several frequently appealed topics, especially within Medicare cost reporting and reimbursement disputes:

• Disproportionate Share Hospital (DSH) payments.
  • Medicaid eligible days
  • 1115 waiver days
  • Part C days
  • SSI entitled days
• Wage index.
• Graduate Medical Education / Indirect Medical Education.
• Base rate standardized amount and budget neutrality.
• Nursing and allied health education programs.
• Volume decrease adjustments.
• Quality reporting.

These issues often have significant reimbursement implications, making careful review and timely action especially important.

Cost Report Protested Items

Another important concept covered in the webinar is the protested item.

Under Medicare cost reporting rules, providers must include an appropriate claim on the cost report in order to preserve the right to reimbursement. An appropriate claim may involve:

• Claiming an item as an allowable cost, or
• Self-disallowing by claiming it as a protested amount when the provider believes the MAC lacks authority or discretion to award reimbursement

This step is critical because failing to properly protest an item may affect appeal rights later.

Cost Report Reopenings

A reopening is another tool available to providers after a cost report has been finalized.

Under 42 CFR § 405.1885, MACs may reopen a provider’s Medicare Cost Report:

• At the request of a provider.
• By CMS direction.
• Through MAC determination.

Reopening Time Limits

• Generally, a reopening must occur within 3 years of the Notice of Final Determination (NPR).
• There is no time limit in cases involving fraud or similar fault.

Important Distinction

A reopening does not toll the PRRB appeal filing deadline. In other words, requesting a reopening does not extend the time to file an appeal.

Providers may request a reopening and still pursue an appeal, but both processes should be managed carefully and strategically.

Key Takeaways from the Webinar

• Make sure the right team members and outside personnel are involved in filing and maintaining appeals.
• Ensure your organization understands the rules and knows which issues may be appealed to the PRRB.

Given the complexity of Medicare Cost Report disputes, organizations benefit from having a defined process for issue identification, documentation, and decision-making.

Final Thoughts

Cost report appeals and reopenings can play a meaningful role in protecting reimbursement, but only when healthcare providers understand the rules, deadlines, and procedural requirements. A proactive approach can help organizations preserve appeal rights, strengthen compliance, and improve reimbursement outcomes.

If your organization is evaluating a cost report issue, it’s important to assess early whether the matter belongs in a protested item, a PRRB appeal, or a reopening request.

Contact the expert team at Besler Holdings for more information or help with your organization’s Medicare Cost Report appeal and/or reopening.

Future Related Webinars

Join us for these free upcoming webinars – offering CPE!

Medicare Cost Report Reopenings & Appeals: Commonly Appealed Issues – A Deep Dive (Part 2) – June 17, 2026, at 1 PM ET

Medicare Cost Report Reopenings & Appeals: Best Practices (Part 3) – July 22, 2026, 1 PM ET

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