All covered entities (CE) and child sites are required by the 340B statute, administered by HRSA, to recertify annually for the 340B program. Failure to do so, will result in removal from the 340B program. The 2018 recertification window runs from August 15, 2018 - September 12, 2018.
The 2019 IPPS Final Rule was put on display for public inspection on August 2, 2018 and is scheduled to be published in the Federal Register on Monday, August 17, 2018. The pre-publication version can be viewed HERE (Medicare DSH begins on page 969). SCA will be reviewing and analyzing the details of the final rule and its components and we will provide more detailed conclusions soon.
On Tuesday, June 19, 2018, the Senate HELP Committee held a hearing on the “Effective Administration of the 340B Drug Pricing Program”, featuring the testimony of only Captain Krista Pedley, Director of HRSA Office of Pharmacy Affairs. The theme of the hearing focused on HRSA’s oversight of the 340B program and the necessary data points needed to measure the program according to its Congressional intent.
HHS Secretary, Alex Azar, appeared before the Senate HELP committee on Tuesday, June 12, 2018 to provide testimony regarding the details of the Trump Administration’s drug pricing blueprint. The hearing was more of a launching point to further the discussion on the topic of lowering drug costs. No definitive action plans were outlined, but a myriad of potential target areas were discussed.
As CMS promised, Worksheet S-10 is now starting to be used for computing uncompensated care allocations and potentially other payment allocations in the future. It is becoming apparent that hospitals need to return to focusing more on their cost reports that are being filed to ensure costs are properly stated.
Over the past decade, many hospitals may not have focused as much on cost and charges due mostly to having PPS payment systems (excluding a discussion on Medicaid payments). While filing complete and accurate cost reports has always been the norm, now more than ever, facilities need to begin looking closer at their cost to charge ratios to ensure they are capturing all costs that can be considered allowable. Are you capturing all your allowable costs to properly compute your cost to charge ratio for S-10?
Southwest Consulting Associates has been endorsed by the Texas Hospital Association to help Texas hospitals thoroughly and completely calculate and document uncompensated care costs to qualify for Medicaid supplemental payments. Read the full press release HERE.
Topics: worksheet s-10
The 2019 IPPS Proposed Rule will be published in the Federal Register on May 7, 2018. If finalized, these changes will go into effect October 1, 2018. The pre-published version can be viewed HERE. Public comments will be accepted until 5 p.m. EDT on June 25, 2018. Below is SCA’s "as brief as we could make it", yet comprehensive summary on the Medicare DSH/Uncompensated Care payment portion (pages 818-877) of the proposed rule as it will affect qualifying DSH hospitals.
The 2019 IPPS Proposed Rule was put on display for public inspection on April 24, 2018 and is scheduled to be published in the Federal Register on Monday, May 7, 2018. The pre-publication version can be viewed HERE. All public comments to the proposed rule are to be received by 5 p.m. EST on Monday, June 25, 2018.
In regards to the Medicare DSH/UC payment, Worksheet S-10 will be used to calculated two-thirds of a qualifying provider's Factor 3. SCA will be reviewing and analyzing the full details of the proposed rule and its components, and we will provide our conclusions in the coming week.
In discussions that we have had externally, there seems to be confusion around which cost reporting periods are applicable to a specific Federal Fiscal year (FFY). The FFY begins 10/01 and ends 09/30, so if your hospital's FYE is not 9/30, how do you know which of your cost reports falls into a specific FFY?
Topics: Medicare DSH Reimbursement
The Senate Health, Education, Labor and Pensions (HELP) Committee held a hearing March 15, 2018, with witnesses from America's Essential Hospitals, Carolina Health Centers, Inc., American Society of Health-System Pharmacists, and the Pharmaceutical Research and Manufacturers of America. The committee asked pertinent questions regarding the purpose and transparency of the 340B drug discount program to the following individuals: