Resumption of CERT Audits May Involve Claims Subject to PHE Flexibilities  

Situation Report | March 1, 2021

Beginning August 11, 2020, the U.S. Centers for Medicare and Medicaid Services (CMS) resumed Comprehensive Error Rate Testing (CERT) program activities that were temporarily suspended in response to the public health emergency (PHE).   

Specifically, the CERT program resumed documentation request letters and phone calls to Medicare providers requesting medical documentation for submitted claims in reporting years 2021 (July 1, 2019 through June 30, 2020) and 2022 (July 1, 2020 through June 30, 2021).

This includes the time period for claims that could reflect PHE waivers and flexibilities afforded to providers as well as some new provider requirements. Among these are the election statement addendum for hospice claims and home health claims that may have certifications and face-to-face encounters completed by allowed non-physician practitioners (NPP).

If an HCA member receives a CERT review decision that is not consistent with their understanding of any billing requirements — especially PHE allowances and the hospice election statement addendum — please e-mail HCA Vice President for Finance and Management Patrick Conole (at in addition to following the routine appeals process. 

For CERT, requested documents are due within 45 calendar days of the request. However, the CERT program has the discretion to grant extensions to providers who need additional time to comply with the request. Impacted providers should contact the CERT Documentation Center Customer Service to identify any hardships or additional time needed with responding to a CERT documentation request. 

CMS will continually evaluate the CERT program activities to gauge whether any future suspension might again become necessary. Based on the cutoff dates for annual improper payment reporting, providers will have until August 2021 to submit documentation on claims in the 2021 reporting year period and until August 2022 for claims in the 2022 reporting year period. 

HCA will update the membership as additional information becomes available.