Southwest Consulting Associates was featured in the latest issue of the First Illinois Speaks HFMA chapter magazine. Beginning on page 12, Kyle Pennington briefly reviews the FY 2020 IPPS proposed rule, summarizes the inaugural audits of 2015 Medicare cost report Worksheet S-10 data and what's coming up next for hospital providers and their reimbursement teams. We’ve also included a post-article update at the end of this post.
You can find a digital copy of the magazine here.
With regards to the 2020 IPPS proposed rule, CMS has proposed to abandon the average of three cost reporting periods as mentioned in the article and use only one year of S-10 data from FY 2015 (or alternatively, FY 2017 data) for FY 2020 UC allocation purposes. Comments on the 2020 IPPS proposed rule were due by June 24, and we anticipate that the final rule will be published in early August as in years past.
At the end of the article, it was noted that the inaugural round of FY 2015 S-10 audits had concluded and that CMS was continuing full steam ahead and moving on to FY 2017 data. CMS had instructed MACs to reach out to certain providers where their 2017 S-10 data appeared aberrant and asked those hospitals to justify its reporting fluctuations to the MAC and if necessary, amend their 2017 report.
Since the time this article was written, we have also learned that not only did MACs review 2017 potentially aberrant S-10 data, they also proceeded with a full roll out 2017 S-10 audits. We began hearing from our client hospitals a few weeks ago that the MAC audits of Worksheet S-10 were starting for FY 2017. We've heard that roughly 600 hospitals will be audited this round, although we suspect that number is higher based on the audit count we've seen on behalf of our clients and other providers that have contacted SCA. Several hospitals that were selected for FY 2015 S-10 audits were also selected for FY 2017 but there have also been a good amount of first-timers in the 2017 S-10 audit pool. So far, the 32 S-10 MAC audit letter requests we’ve seen (5 different MACs) essentially mirror the initial requests for data for FY 2015, with a few minor exceptions. It appears the process and data required will be very similar to FY 2015 (stay tuned for posts comparing the 2015 vs the 2017 audit letters and what the audit findings were). It’s likely these 2017 audits will be wrapped by or before the end of December and uploaded to HCRIS by 12/31.
We’re also hearing that audits of FY 2018 forward will be increased significantly. In fact, we have heard from different MACs that FY 2018 S-10 data will be audited for ALL hospitals (similar to Wage Index).
And as a reminder, CMS will require hospitals to submit a detailed listing of charity patients for cost reports with periods beginning on or after October 1, 2018, or the report will be rejected.
Of course, it’s still a guess as to what CMS will decide in its final rule with regard to 2015 v. 2017 S-10, but the audits of 2017 could suggest that they’re leaning toward using 2015. The 2017 audits would likely not impact the 2020 final rule due to the timing, but we’ll probably have to wait until August to know for sure. What we can infer is that CMS is tightening the screws on Worksheet S-10 data.
We are gearing up for our next webinar on the 2020 IPPS rule and Worksheet S-10. If you have not already, save your seat by clicking the link below.