Southwest Consulting Associates Blog

FY 2020 IPPS Proposed Rule

Posted by Jamie Pennington on Apr 24, 2019 3:23:43 PM

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2020 IPPS proposed ruleThe FY 2020 Inpatient Prospective Payment System (IPPS) Proposed Rule was put on display for public inspection on April 23, 2019, and is scheduled to be published in the Federal Register on May 3, 2019.  The pre-publication version can be viewed HERE or on the FY 2020 IPPS Proposed Rule homepage.  If finalized, these changes will go into effect October 1, 2019.  All public comments to the proposed rule are to be received by 5 pm EST on Monday, June 24, 2019.


After an initial review, here are the highlights regarding the Medicare DSH and Uncompensated Care Payments which begin on page 869 of the pre-publication version mentioned above:

  1. The uncompensated care pool to be distributed to qualifying hospitals has been established at $8.5 billion, which is a increase of $216 million from the FY 2019 Final rule.

  2. CMS is phasing out the use of low-income days to calculate a hospital's Factor 3.

  3. CMS is proposing using only one year of Medicare cost report Worksheet S-10 data versus a three-year blend as it had in the past.

  4. They are proposing the use of S-10 data from FY 2015 cost reports.

  5. As an alternative, CMS is also seeking comments about the use of S-10 from FY 2017 cost reports.

  6. CMS is also seeking public comments on ways to reduce Provider Reimbursement Review Board (PRRB) appeals related to a hospital's Medicaid fraction.

As a reminder, hospitals have 60-days to submit their comments on the full FY 2020 IPPS Proposed Rule including notifying CMS of any inaccuracies in the data files used as part of the rule.  Per the rule, "to be assured consideration, comments must be received at one of the addresses provided in the ADDRESSES section, no later than 5 p.m. EDT on June 24, 2019."


Southwest Consulting Associates will be reviewing and analyzing the details of the proposed rule in its entirety including data components, and will be providing follow up details and conclusions in future posts.  Stay tuned and be sure to subscribe to our blog below to get those posts sent directly to your inbox.

Southwest Consulting Associates Worksheet S-10 blog


Additionally, SCA is putting together our annual proposed rule webinar happening in May.  If you have not already, please save your seat below and we will notify you once the date, time and registration link are available.

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Topics: Medicare DSH Reimbursement, Industry Updates, S-10, regulations, proposed rule, worksheet s-10, factor 3, uncompensated care payment, ipps rule, provider reimbursement

About This Blog

The climate of provider reimbursement is ever-changing and this blog is intended to keep you up-to-date on the latest information regarding:

  • DSH Reimbursement
  • 340B Pharmacy Drug Discount Program
  • Compliance Issues
  • Litigation Surrounding Provider Reimbursement

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