Questions concerning the process of requesting exceptions from the skilled nursing facility cost limits

The new PRM provisions provide helpful guidance to SNFs in submitting requests for exceptions to cost limits. However, they also make the process more rigid and create procedural traps for the unwary. Accordingly, SNFs are advised to study the PRM sections to assure that their exception requests contain the required information. However, they should not feel bound by the limits in the PRM. When submitting requests, SNFs should think creatively about why their facilities are atypical and how to best quantify their higher costs. They should then protect their rights by including these more creative theories or calculations in the materials they submit to the intermediaries.