Southwest Consulting Associates is pleased to announce their Associate Membership with HAPevolve, of the Hospital & Healthsystem Association of Pennsylvania (HAP) effective immediately. The partnership is expected to enhance the value the Hospital & Health System Association of Pennsylvania offers its hospital members through reimbursement savings optimization programs and education provided by Southwest Consulting Associates.
Topics: News & Events
On January 23, 2015, Michael Newell, SCA’s President, authored a blog article entitled 340B meets S-10, which can be found HERE. The impetus for this article was a report published by the Alliance for Integrity and Reform of 340B (AIR340B). In this article, the authors concluded that 340B hospitals appear to provide only a minimal amount of charity care thus calling into question whether or not Congress’ intentions for the 340B program are being met. The data used to reach this conclusion was derived from the Medicare Cost Report, CMS-2552-10, S-10 – the very data that CMS currently uses as the basis to allocate the uncompensated care pool for the Medicare DSH/uncompensated care program.
The Centers for Medicare and Medicaid Services (CMS) has posted a Questions and Answers document providing clarification related to Medicare Cost Report Worksheet S-10. If you’ll recall, CMS issued Transmittal 11 in September 2017 that made a number of revisions to the instructions for reporting data on cost report Worksheet S-10.
On Friday, December 1, 2017, CMS released Transmittal 1981, which clarifies the deadlines for uploading revised or initial submissions of FY 2014 and FY 2015 cost report Worksheet S-10. For revisions to be considered, CMS extended the deadline to Tuesday, January 2, 2018, for all IPPS hospitals to submit the data to their Medicare Administrative Contractor (MAC). On December 4, 2017, the provider education article, MM10378, was released related to this instruction.
It is fitting that the month of Thanksgiving also begins the 4th year of SCA's healthcare blog. We thank you, the readers, for being a part of our story as we share the latest in Medicare DSH reimbursement, Worksheet S-10 uncompensated care and 340B drug pricing program news. You trust us with your time, and we appreciate being a source of insight in this ever-changing industry. As we celebrate our 3rd anniversary and start to our 4th year, let's take a look at how far we have come, together.
On October 20, 2017, CMS issued another Technical Direction Letter (TDL) extending the deadline for all IPPS hospitals to submit revised or initial FFY 2014 and 2015 Worksheet S-10’s to January 2, 2018. Southwest Consulting Associates confirmed this directly with CMS' Division of Acute Care and is monitoring the CMS website for a posted notice, which CMS also stated would be available shortly. Until the official notice is posted, please contact your MAC for additional information.
Last week, September 29, 2017, CMS issued Transmittal 11 that makes a number of revisions to the instructions for reporting data on cost report Worksheet S-10. These instructions need to be incorporated into any FFY 2014 & FFY 2015 Worksheet S-10 revisions providers are working to submit by the October 31, 2017 deadline and then for any future year submissions. In particular, the changes include:
As a result of Hurricanes Harvey, Irma and Maria, CMS posted a notice on its website last month granting a 31-day extension to IPPS hospitals in Texas, Louisiana, Florida, Georgia, South Carolina, Puerto Rico and the U.S. Virgin Islands to submit FFY 2014 and FFY 2015 revised Worksheet S-10's. CMS subsequently issued a Technical Direction Letter (TDL) extending the same 31-day extension to file updated FFY 2014 and 2015 Worksheet S-10’s to October 31, 2017 for ALL IPPS providers.
Earlier this week, CMS posted a notice on its website granting a 31-day extension to IPPS hospitals in Texas, Louisiana, Florida, Georgia, South Carolina, Puerto Rico and the U.S. Virgin Islands to submit FFY 2014 and FFY 2015 Worksheet S-10's. This comes on the heels of Hurricane Harvey, Irma and Maria, the President declaring a state of emergency and the HHS Secretary declaring a public health emergency for Texas, Louisiana, Florida, Georgia, South Carolina, Puerto Rico and the U.S. Virgin Islands. Both the President and HHS Secretary's actions allow CMS to put in place programmatic waivers based on Section 1135 of the Social Security Act.
The Government Accountability Office (the audit, evaluation, and investigative arm of Congress) examines the use of public funds; evaluates federal programs and policies; and provides analyses, recommendations, and other assistance to help Congress make informed oversight, policy, and funding decisions. As part of their mandate, they monitor and review the 340B drug discount program to determine if there are any issues with integrity and oversight and offer recommendations for greater compliance. In 2011, the GAO gave specific recommendations for HRSA. How much has been done and what is next for the 340B program?