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?
CMS published new instructions stating that Worksheet S-10 data will be used in the uncompensated care calculation as part of Factor 3. As such, facilities need to take note and begin more analysis around their costs for the cost to charge ratios and the S-10 overall cost to charge ratio that drives the calculation of uncompensated care. Some of the items that come to mind to pay close attention to are items such as:
Worksheet A Expenses - If a hospital is setting up non-reimbursable cost centers for such items as Marketing, Physician Private Offices, etc., the facility may want to review these costs to ensure they truly are non-reimbursable. If it is found that the non-reimbursable cost center does not meet the regulations for being set up as a separate cost center, the facility can potentially look into other methods of adjusting for these costs if truly non-reimbursable. In doing this, the hospital would then be properly reflecting the allocation of cost from the overhead departments.
Worksheet A-8-2 Provider Based Physician Adjustment - If a hospital is including the physician costs all as “professional” then the facility could potentially be missing out on allowable costs to include.
Worksheet B-1 Statistics - Facilities should review their statistical basis and allocations to determine if they are stepping down overhead to the allowable and non-reimbursable areas like they should.
There are many additional areas a hospital can review to determine if all allowable costs have been properly captured on the cost report and in accordance with program instructions. If not already, hospitals should begin reviewing their federal fiscal years 2016 and 2017 cost reports to ensure they have filed them with the most accurate accounting of costs. If an adjustment is noted and there is a necessity to amend, the facility should ensure that revisions are completed so that the numbers will be appropriately stated for calculating the uncompensated care amount on Worksheet S-10.
Here at Southwest Consulting Associates (SCA) we have several blogs regarding S-10. Of particular interest may be:
These have information regarding all the Worksheet S-10 changes that happened over the course of 2017, in addition to a change that dealt with transaction history and what to include. CMS switched the timing from transactions written off for service dates within the hospital cost report year to any charity transaction written off in the current year cost report with no consideration of the date of the service.
SCA assists hospitals with full provider reimbursement support including allowable costs and cost to charge ratio reviews. If you would like to discuss this blog further or how SCA can assist your hospital with your provider reimbursement needs, please contact Mike Newell at 972-732-8100 or you can send an email here.
We will be posting more about the cost to charge ratio in the coming weeks. When was the last time you reviewed your CCR? How often do you review? Share your story below and then, subscribe to our blog (if not already) so you don't miss the next post.