Avoid Costly CMS 1728-20 Form Errors: The Ultimate HHA Filing Guide

Quick answer: The CMS 1728-20 form is the Medicare Home Health Agency Cost Report used by freestanding home health agencies to report annual financial, statistical, utilization, and reimbursement data. It is not a patient claim form and should not be confused with the CMS-1500 professional claim form. Most agencies prepare the cost report with CMS-approved electronic cost report software and submit the complete filing package to their Medicare Administrative Contractor, often through the Medicare Cost Report e-Filing system, or MCReF.

For home health agencies, the CMS 1728-20 form is more than an annual administrative requirement. It connects your accounting records, payroll data, patient visits, Medicare payments, cost allocations, and supporting documentation into a report that can affect settlement calculations and future reimbursement analysis.

That complexity is why searching for a simple “fillable form CMS 1728-20” can be misleading. Although CMS publishes official forms and instructions, a full-utilization cost report generally cannot be handled like a basic PDF application. It must follow Medicare cost-reporting rules, electronic file specifications, required edits, and Medicare Administrative Contractor acceptance standards.

This guide explains what the CMS 1728-20 form is, who must file it, where to find the official version, how to prepare it correctly, how digital submission works, and which common mistakes can cause rejection or additional review.

Important: This article provides general educational information. Your agency should confirm requirements with its Medicare Administrative Contractor, accountant, cost report specialist, or legal adviser.

CMS 1728-20 Form vs. CMS-1500 Claim Form

A major source of confusion is the similarity between Medicare form numbers. The CMS 1728-20 form is sometimes incorrectly described online as a medical insurance claim form or professional billing form.

That description is incorrect.

The CMS 1728-20 is an annual institutional cost report for qualifying home health agencies. The CMS-1500 is the standard paper claim form used by physicians, noninstitutional providers, and suppliers when paper professional claims are permitted.

Question	CMS 1728-20	CMS-1500
Primary purpose	Annual Home Health Agency cost reporting	Professional healthcare claim submission
Typical user	Freestanding Medicare-certified HHA	Physicians, practitioners, and suppliers
Reporting level	Organization-wide financial and statistical data	Individual patient services and charges
Filing frequency	Generally annual	Submitted as services are billed
Main data	Expenses, visits, costs, payments, financial statements, and settlement data	Patient, insurance, diagnosis, procedure, provider, and charge data
Electronic equivalent or system	Electronic Cost Report and MCReF submission	HIPAA 837P professional claim
Main instructions	CMS Provider Reimbursement Manual, Part 2, Chapter 47	Medicare Claims Processing Manual, Chapter 26

This distinction should be made near the beginning of any CMS 1728-20 resource. It answers a common search question while preventing home health administrators from downloading the wrong form or following claim-level instructions that do not apply to annual cost reporting.

What Is the CMS 1728-20 Form?

The CMS 1728-20 form is the Medicare cost report designed for freestanding Home Health Agencies. CMS uses the report to collect information about an agency’s operations, costs, utilization, Medicare payments, and financial position.

Medicare-certified institutional providers are generally required to submit annual cost reports to their Medicare Administrative Contractors. CMS then maintains cost report information in the Healthcare Provider Cost Reporting Information System, commonly known as HCRIS. The data can include facility characteristics, utilization, costs and charges by cost center, Medicare settlement information, and financial statement data.

The current CMS 1728-20 instructions apply to relevant cost reporting periods beginning on or after January 1, 2020, and ending on or after December 31, 2020. The form replaced the older CMS 1728-94 format for applicable reporting periods.

CMS continued to revise the form and its electronic specifications after the initial release. A May 2026 transmittal clarified instructions for Worksheet S-2, Part II, Worksheet D, and Worksheet D-1, while also adding or revising electronic report edits. Those changes apply to cost reporting periods ending on or after June 30, 2026. Agencies should therefore verify that their software and instructions match the period being reported.

What Is the Purpose of the CMS 1728-20 Cost Report?

The form helps Medicare evaluate the costs associated with furnishing services to Medicare beneficiaries and calculate amounts that may be due to or from the provider.

The report also creates standardized data that CMS can use for program administration, reimbursement analysis, rate development, and payment refinement. Cost report information can be especially valuable because it connects financial statements with agency-level patient activity and Medicare payment information.

For an HHA, the practical purposes of the report include:

1. Reporting organizational and provider identification information.
2. Presenting patient visit, census, employee, and service-area statistics.
3. Reconciling expenses from the general ledger and trial balance.
4. Reclassifying and adjusting costs when required.
5. Allocating overhead and general service costs to revenue-producing cost centers.
6. Calculating Medicare-related costs and payment settlement information.
7. Reporting the balance sheet, revenue, and expenses.
8. Disclosing related-party transactions, home office allocations, and applicable bad debts.
9. Providing information that can be reviewed or audited by the Medicare Administrative Contractor.

The cost report is not simply a copy of the agency’s tax return or financial statements. It reorganizes information according to Medicare reimbursement principles, defined cost centers, statistical allocation methods, and program-specific instructions.

Who Must File Form CMS 1728-20?

CMS instructions state that the form must be used by freestanding Home Health Agencies subject to Medicare cost-reporting requirements.

An HHA that is part of another healthcare complex may need a different cost report:

• A hospital-based HHA generally reports through Form CMS-2552.
• An HHA that is part of a Skilled Nursing Facility healthcare complex generally reports through Form CMS-2540.
• A freestanding HHA generally uses Form CMS-1728-20.

The distinction matters because choosing the wrong cost report can affect worksheet requirements, electronic specifications, supporting schedules, and filing acceptance.

Low-utilization or no-utilization agencies should not assume that they are automatically exempt. CMS instructions provide specific handling for full, low, or no Medicare utilization. Low-utilization reporting may require prior contractor approval, and manual preparation is limited to certain low-utilization, no-utilization, or hardship situations.

An agency should ask its Medicare Administrative Contractor for guidance when it has:

• Recently received its Medicare certification.
• Completed a change of ownership.
• Terminated participation in Medicare.
• Had little or no Medicare activity.
• Added or closed an HHA-based hospice.
• Received allocations from a home office or chain organization.
• Operated for a shortened cost reporting period.
• Changed its fiscal year-end.

When Is the CMS 1728-20 Form Due?

Cost reports are generally due on or before the last day of the fifth month following the close of the reporting period. When a reporting period ends on a date other than the last day of a month, the report is generally due 150 days after the end of the cost reporting period.

For example:

• A calendar-year HHA with a December 31 year-end would generally have a May 31 due date.
• An HHA with a September 30 year-end would generally have a due date on the last day of February.
• An agency with a short reporting period ending in the middle of a month should calculate 150 days from the closing date.

Due dates should be confirmed directly with the MAC, particularly following a change of ownership, termination, approved reporting-period change, natural disaster, or other unusual event.

A cost report should not be treated as complete merely because files were uploaded. Under the cost-reporting rules, an electronic report must satisfy the applicable filing and acceptance requirements. The MAC reviews the package and makes an acceptability determination, generally within 30 days of receipt.

Where Can You Download the Official CMS 1728-20 Form?

The safest source is the official CMS website.

CMS maintains a dedicated CMS-1728-20 page identifying the document as the Home Health Agency Cost Report. CMS also publishes Chapter 47 of the Provider Reimbursement Manual, Part 2, which includes the form instructions, worksheets, and Electronic Cost Report specifications.

When downloading the form, verify:

• The form number is CMS-1728-20.
• The instructions apply to the reporting period being prepared.
• Any current transmittals have been reviewed.
• Your cost report software supports the applicable CMS transmittal.
• You are not using an unofficial file presented as a professional claim form.

The official PDF may be useful for reviewing the worksheet layout, but a full electronic filing generally requires approved cost report software that can generate the ECR file, print image, certification information, and required edits.

The current form displays OMB control number 0938-0022 and an expiration date of January 31, 2027. Since forms and approvals can be renewed or revised, agencies should always retrieve the latest version rather than relying on a locally saved copy from a prior year.

Is There a Fillable CMS 1728-20 Form?

Searchers often want a blank or fillable CMS 1728-20 template that can be completed directly in a browser or PDF reader. CMS publishes the official forms, but that does not mean a simple PDF is sufficient for a standard full-utilization filing.

The electronic cost report contains structured records and data elements that must comply with CMS specifications. Vendor software is expected to automate mathematical accuracy edits, minimum file requirements, and other CMS data edits.

A PDF can still be useful for:

• Reviewing worksheet questions.
• Planning data collection.
• Identifying supporting schedules.
• Training internal staff.
• Conducting a preliminary review.
• Comparing year-over-year reporting.

It should not replace current CMS-approved software or professional cost report preparation when an electronic report is required.

What Information Is Needed Before Completing the Form?

Cost report preparation becomes much easier when the data is collected and reconciled before it is entered into the software.

The following table provides a practical data-readiness checklist.

Data category	Examples of information to collect	Common source
Provider identification	Legal name, address, CCN, NPI, ownership type, certification dates	Enrollment records and prior cost report
Reporting period	Beginning date, ending date, short-period explanation	Accounting records and MAC correspondence
Financial statements	Balance sheet, statement of revenue and expenses, notes	Accounting system or CPA
Trial balance	Detailed account balances mapped to cost centers	General ledger
Payroll and staffing	Salaries, hours, FTEs, employee classifications	Payroll and HR systems
Patient statistics	Visits, patient census, service disciplines, CBSA data	EHR and scheduling system
Medicare utilization	Covered visits, payment categories, charges, outliers	Billing system and PS&R
Revenue	Medicare, Medicaid, commercial, private pay, and other program revenue	Billing and accounting systems
Payments	Interim payments, receivables, adjustments, and refunds	Remittance and payment posting records
Contracted services	Therapy, nursing, medical social services, and other contractors	Accounts payable and contracts
Related-party activity	Management fees, rent, supplies, home office allocations	General ledger and ownership records
Fixed assets	Depreciation, leases, equipment, building costs	Fixed-asset ledger
Bad debts	Eligible Medicare deductible or coinsurance balances	Patient accounting and collection records
Supporting documents	Financial statements, reconciliations, bad debt exhibit, allocation schedules	Finance, billing, and compliance teams

CMS estimates that completing the information collection averages 195 hours per response, including reviewing instructions, gathering information, completing the report, and reviewing it. The estimate demonstrates why cost report preparation should begin well before the filing deadline.

How Do You Complete a CMS 1728-20 Form Correctly?

CMS provides a recommended sequence for completing the worksheets. Following that sequence is important because many later calculations depend on figures entered or allocated on earlier worksheets.

Step 1: Confirm the correct reporting entity and period

Begin by confirming that the agency is a freestanding HHA that should use CMS 1728-20. Verify the legal name, CCN, NPI, ownership structure, Medicare certification dates, and reporting-period dates.

Compare this information with:

• The prior-year cost report.
• Provider enrollment records.
• MAC correspondence.
• Financial statements.
• Any change-of-ownership documents.
• Any approval for a different fiscal year-end.

A mismatch in the CCN or reporting dates can cause problems throughout the filing package.

Step 2: Complete Worksheet S-2 identification and reimbursement data

Worksheet S-2 collects identifying, organizational, and reimbursement-related information.

This worksheet can include:

• Provider address and certification information.
• Type of ownership or control.
• Contracted therapy relationships.
• Related-organization transactions.
• Malpractice insurance information.
• Home office or chain allocations.
• Change-of-ownership information.
• Medicare termination information.
• Financial statement status.
• Bad debt questions.
• Supporting-document requirements.

When a question requires documentation, label the attachment with the worksheet, part, and line it supports. CMS instructions specifically direct providers to connect supporting information to the relevant S-2 line.

Do not automatically copy answers from the previous year. Ownership, related-party arrangements, outside therapy agreements, insurance policies, and home office relationships may have changed.

Step 3: Complete Worksheet S-3 statistical data

Worksheet S-3 reports HHA statistical information. Depending on the applicable worksheet parts and reporting period, information may include:

• Patient visits by discipline.
• Patient census information.
• Full-time-equivalent employees.
• Contract labor statistics.
• Service-area and CBSA information.
• Prospective payment activity.
• Occupational category data.

The billing system, EHR, payroll records, and general ledger should agree on the basic operational story.

For example, reported nursing salaries, nursing FTEs, nursing visits, and nursing revenue do not have to move in identical proportions, but significant inconsistencies should be investigated and documented.

Step 4: Complete Worksheet S-4 when applicable

Worksheet S-4 relates to HHA-based hospice statistical information. Agencies without an HHA-based hospice may not need the applicable hospice worksheets.

Do not include blank worksheets simply because they are part of the complete form package. CMS instructions state that worksheets not completed because they are inapplicable should not be included as blank worksheets in the assembled report.

Step 5: Build and map the trial balance to Worksheet A

Worksheet A records the trial balance of expense accounts from the HHA’s accounting books and records. It also provides for reclassifications and adjustments before cost-finding calculations. CMS instructs providers to submit the working trial balance with the cost report.

This is one of the most important preparation stages.

Every general ledger expense account should be mapped to an appropriate Medicare cost center. The mapped trial balance should reconcile to the accounting records before reclassifications and adjustments are applied.

Common cost-center categories may include:

• Administrative and general.
• Plant operations and maintenance.
• Transportation.
• Capital-related building costs.
• Capital-related movable equipment.
• Skilled nursing.
• Physical therapy.
• Occupational therapy.
• Speech-language pathology.
• Medical social services.
• Home health aide services.
• Medical supplies.
• Other reimbursable or nonreimbursable services.

Avoid mapping large numbers of accounts into a general “other” category without analysis. Poor mapping can distort allocation results and make year-over-year comparisons difficult.

Step 6: Enter expense reclassifications on Worksheet A-6

Reclassifications move costs from one cost center to another without changing the total expenses reported.

For example, a salary may initially appear in administrative and general expense but need to be divided between administration and a direct service cost center based on the employee’s documented responsibilities.

Every reclassification should have:

• A clear explanation.
• A source cost center.
• A destination cost center.
• A supportable allocation basis.
• Documentation that can be reproduced during review.

The total increases and decreases should reconcile.

Step 7: Complete related-party disclosures and adjustments

Worksheet A-8 is used for adjustments to expenses. Worksheet A-8-1 addresses related organizations and home office or chain relationships.

Related-party costs require careful review because Medicare cost principles can limit reimbursable amounts. Common examples include:

• Rent paid to an entity owned by an agency shareholder.
• Management services provided by an affiliated company.
• Supplies purchased from a related organization.
• Administrative services allocated from a parent company.
• Shared employees or facilities.
• Home office costs distributed among multiple providers.

A transaction is not automatically allowable merely because the agency paid an invoice. The amount, relationship, business purpose, and applicable Medicare cost principles must be considered.

Step 8: Allocate overhead through Worksheets B and B-1

Worksheets B and B-1 distribute general service costs to revenue-producing cost centers using approved statistical bases.

Examples of potential allocation statistics include:

• Square footage.
• Time studies.
• Salaries.
• Employee counts.
• Direct costs.
• Miles.
• Hours.
• Accumulated costs.

The statistical basis should reasonably connect the overhead expense with the departments benefiting from it.

An allocation method selected only because it produces a favorable result may not be defensible. Use consistent methodologies, maintain supporting schedules, and document any change from the prior year.

Step 9: Calculate program costs on Worksheet C

Worksheet C calculates aggregate HHA cost per visit and Medicare cost information. It can also address applicable supplies, drugs, or disposable device costs.

The accuracy of Worksheet C depends heavily on:

• Correct cost allocation.
• Reliable visit data.
• Proper Medicare utilization data.
• Accurate charges.
• Correct classification of services.
• Consistency with the PS&R and billing system.

Before accepting the calculated result, compare costs per visit by discipline with the prior year and investigate major changes.

Step 10: Complete Worksheets D and D-1

Worksheet D calculates reimbursement settlement information. Worksheet D-1 analyzes payments received for services rendered to Medicare beneficiaries.

The calculation may include:

• Prospective payment amounts.
• Outlier payments.
• Other Medicare payments.
• Certain separately reimbursed services.
• Primary payer amounts.
• Deductible and coinsurance information.
• Interim payments.
• Amounts due to or from Medicare.

CMS clarified portions of Worksheets D and D-1 in its 2026 Chapter 47 update, so agencies preparing periods ending on or after June 30, 2026 should confirm that they are following the revised instructions and current software edits.

Reconcile payment figures to the PS&R, remittance records, receivables, and general ledger. Unexplained differences should be resolved before submission.

Step 11: Complete Worksheets F and F-1

Worksheet F is the balance sheet. Worksheet F-1 reports revenue and expenses.

CMS directs providers to prepare Worksheet F from the HHA’s accounting books and records and to keep it consistent with the financial statements where applicable.

The balance sheet should balance, and the revenue and expense figures should reconcile with the trial balance and submitted financial statements.

When cost report totals differ from the financial statements, prepare a clear reconciliation. Common reconciling items may include:

• Nonallowable cost adjustments.
• Reclassifications.
• Related-party limitations.
• Home office allocations.
• Different presentation classifications.
• Cost report-only adjustments.

Step 12: Complete HHA-based hospice worksheets when applicable

The O-series worksheets apply to HHA-based hospice operations and include analysis, cost allocation, apportionment, and per diem calculations.

An agency with HHA-based hospice activity should verify that hospice days, costs, shared services, and levels of care are separately and consistently supported.

Step 13: Complete Worksheet S certification and settlement summary last

CMS places Worksheet S at the end of the recommended completion sequence.

Worksheet S includes:

• Cost report status.
• Certification.
• Settlement summary.

The settlement amount is transferred from Worksheet D. The certification must be reviewed and signed by the appropriate administrator or chief financial officer after the report has been completed.

The signer should not treat certification as a routine administrative signature. The form contains a formal statement regarding the accuracy, completeness, and lawful preparation of the report.

Can the CMS 1728-20 Form Be Submitted Online?

Yes. Medicare Part A providers can use the Medicare Cost Report e-Filing system, or MCReF, to transmit their Medicare cost report package and supporting documentation directly to the MAC.

CMS states that MCReF can receive the complete package, including supporting materials, for qualifying fiscal year-ends. A successful submission is immediately received by the MAC so that the cost report acceptance process can begin.

A filing package may include:

• The Electronic Cost Report file.
• The print image file.
• The signed certification page or approved electronic certification.
• Financial statements.
• Working trial balance.
• Reconciliation schedules.
• Medicare bad debt exhibit, when applicable.
• Home office documentation.
• Related-party information.
• Other supporting schedules requested by CMS or the MAC.

Files uploaded through MCReF should not be encrypted or password protected because MCReF is already a secure transmission portal. CMS guidance also warns that duplicate submissions may be rejected and that timely receipt is measured according to the submission deadline.

Before submitting, confirm that:

1. The ECR was generated using a current approved software version.
2. The ECR passes all required Level 1 edits.
3. The print image matches the ECR data.
4. The certification page contains the correct signature.
5. The ECR encryption code and certification information match.
6. Required supporting documentation is included.
7. File names have not been changed in a way that prevents automatic recognition.
8. The package is uploaded before the due date.
9. The submission confirmation is saved.
10. The agency monitors the filing for MAC acceptance or follow-up requests.

What Software Can Be Used to Complete the CMS 1728-20 Form?

Medicare cost reports should be prepared using software that supports the applicable CMS electronic reporting specifications and current form transmittal.

Published CMS and MAC vendor materials have included products such as:

• Health Financial Systems MCRIF32.
• Optimizer Systems WinLASH.
• Progressive Provider Services Med-Calc.
• Manis & Ryan Spirit of 1728 for certain transmittals.

Approval can be tied to a specific form transmittal and cost reporting period. An agency should therefore verify current approval with its MAC before purchasing software or starting a new report.

When evaluating cost report software or a service provider, ask:

• Does the product support CMS 1728-20?
• Which transmittal and reporting periods are supported?
• Does it generate both the ECR and print image?
• Does it automate required edits?
• Can it import prior-year data?
• Can it import or reconcile PS&R information?
• Does it provide audit trails and supporting schedules?
• Does it support MCReF-compatible files?
• How quickly are CMS revisions implemented?
• Is technical or cost report preparation support available?

The lowest-cost software is not always the least expensive solution. A system that lacks current edits, reconciliation tools, documentation support, or reliable updates may create additional labor and filing risk.

Common CMS 1728-20 Form Errors to Avoid

1. Confusing CMS 1728-20 with CMS-1500

The CMS-1500 is a professional claim form. CMS 1728-20 is an HHA cost report. Downloading CMS-1500 instructions will not help an agency prepare its annual HHA cost report.

2. Using an outdated form or software transmittal

CMS periodically revises worksheets, instructions, electronic specifications, and edits. Software that worked for a previous reporting period may not satisfy current requirements.

3. Starting preparation too close to the deadline

The cost report depends on information from accounting, billing, HR, payroll, clinical operations, ownership records, and outside contractors. Waiting until the final weeks leaves little time to resolve discrepancies.

4. Failing to reconcile the working trial balance

Worksheet A should tie to the agency’s accounting records. Unreconciled trial balance totals can flow through every later worksheet and undermine the reliability of the filing.

5. Mapping expenses to the wrong cost centers

Placing therapy, nursing, supplies, transportation, or administrative expenses in the wrong cost centers can distort cost allocation and cost-per-visit calculations.

6. Unsupported reclassifications

A reclassification should have a logical purpose and documented basis. Round-number allocations or estimates without supporting data are difficult to defend.

7. Inconsistent visit statistics

Visit totals may differ across the EHR, billing platform, scheduling system, payroll reports, and PS&R. Differences should be investigated rather than selecting the most convenient number.

8. Mixing billed, paid, and completed-period information

Claims and payment records can cross fiscal years. CMS instructions for Worksheet D address how certain payments associated with episodes or periods should be reported. Using deposit dates alone may place amounts in the wrong reporting period.

9. Omitting related-party transactions

Common ownership, control, or family relationships can create related-party reporting requirements. Review rent, management fees, equipment, supplies, staffing, and professional service arrangements.

10. Failing to reconcile financial statements with the cost report

When total revenue or expenses differ, submit a reconciliation that clearly explains the differences. Do not expect the MAC to infer the reason.

11. Missing supporting documentation

The ECR alone may not be a complete filing package. Missing financial statements, trial balances, bad debt support, home office information, or reconciliations can affect acceptability.

12. Using the wrong bad debt template

CMS provides an electronic Exhibit 1 specification and template for CMS 1728-20 Medicare bad debts. Agencies claiming eligible Medicare bad debts should use the applicable current format and retain account-level support.

13. Changing ECR file names unnecessarily

MCReF can recognize certain files based on expected naming conventions. Renaming files after they are generated may prevent automatic identification and create upload problems.

14. Mismatched certification and ECR information

The settlement amount, signature information, reporting period, CCN, and encryption code must align with the electronically generated report.

15. Assuming a successful upload means the report was accepted

Upload confirmation establishes transmission, not necessarily final acceptability. Monitor communications from the MAC and respond quickly to requests for corrections or missing documents.

How Better Medical Billing Data Supports Cost Report Accuracy

The CMS 1728-20 is a cost report, but a significant portion of its data originates in the revenue cycle.

Billing operations can affect the reliability of:

• Medicare charges.
• Visit counts.
• Payment-category information.
• Outlier payments.
• Deductible and coinsurance balances.
• Primary payer amounts.
• Accounts receivable.
• Bad debt records.
• Revenue classifications.
• Payment posting.
• PS&R reconciliations.

A poorly controlled billing process can create year-end discrepancies that take weeks to investigate. For example, inconsistent service dates, unposted remittances, unresolved denials, duplicate accounts, or inaccurate payer classifications can make it harder to reconcile billing activity with the general ledger and PS&R.

A stronger process includes monthly reconciliation rather than a single annual cleanup.

Home health agencies should consider reviewing:

1. Billed visits versus completed visits.
2. Medicare payments versus remittance records.
3. Payment posting versus bank deposits.
4. Billing-system revenue versus general ledger revenue.
5. Patient responsibility balances.
6. Credit balances and refunds.
7. Denied and rejected claims.
8. Adjustments and write-offs.
9. Accounts transferred to collections.
10. Medicare bad debt documentation.

Summit Billing Solutions provides outsourced medical billing, claims processing, denial-management, and revenue-cycle support intended to reduce administrative burdens and improve financial performance. Cleaner billing workflows can give an agency and its cost report preparer a more dependable starting point.

A Practical CMS 1728-20 Preparation Timeline

A year-round approach is safer than waiting until the filing deadline.

Throughout the year

Maintain accurate cost-center mappings, reconcile revenue, track related-party transactions, preserve allocation statistics, and review Medicare payments.

Sixty to ninety days before year-end

Confirm the reporting entity, review changes in ownership or operations, verify software requirements, and identify new CMS instructions that may affect the reporting period.

Immediately after year-end

Close the accounting period, prepare the working trial balance, reconcile the balance sheet, collect visit data, obtain PS&R reports, and prepare financial statements.

Sixty days before the deadline

Complete preliminary worksheets, review overhead allocation statistics, reconcile payments, and identify missing documentation.

Thirty days before the deadline

Resolve report edits, complete management review, compare results with the prior year, and finalize supporting schedules.

One to two weeks before the deadline

Generate the final ECR and print image, obtain the authorized certification, upload the package, retain confirmation, and monitor the MAC’s response.

This schedule gives the agency time to correct discrepancies without relying on last-minute estimates.

Frequently Asked Questions About the CMS 1728-20 Form

Final Thoughts

Correctly preparing the CMS 1728-20 form requires more than transferring annual financial totals into a blank template. The report must connect accounting records, statistical data, Medicare payments, cost allocations, financial statements, and supporting documentation under current CMS instructions.

The best way to reduce filing risk is to maintain accurate records throughout the year, reconcile billing and accounting data regularly, use software approved for the applicable reporting period, and perform a complete review before certification.

References

1. Official CMS-1728-20 Home Health Agency Cost Report page
2. CMS Provider Reimbursement Manual, Part 2
3. 2026 CMS Chapter 47 Transmittal for Form CMS-1728-20
4. Medicare Cost Report e-Filing System Information
5. CMS Electronic Cost Report Exhibit Templates
6. CMS Home Health Agency Cost Report Data
7. CMS Professional Paper Claim Form Information
8. 42 CFR 413.24, Adequate Cost Data and Cost Finding