The Hospital Outpatient Prospective Payment System (OPPS) FY 2020 proposed rule was put on display for public inspection on July 29, 2019 and published in the Federal Register on August 9, 2019. The 247-page FY 2020 OPPS proposed rule can be viewed in its entirety here. This proposed rule will affect discharges on or after January 1, 2020.
The FY 2020 Inpatient Prospective Payment System (IPPS) Final Rule was put on display for public inspection on August 2, 2019, and is scheduled to be published in the Federal Register on August 16, 2019. The pre-publication version can be viewed HERE or on the FY 2020 IPPS Final Rule homepage. These changes will go into effect October 1, 2019.
We began hearing from our client hospitals a few weeks ago that the MAC audits of Worksheet S-10 were starting for FFY 2017. Yes, that’s right, reviews of FFY 2015 data are over and we are onto round 2. We've heard that roughly 600 hospitals will be audited this time around, 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 FFY 2015 S-10 audits were also selected for FFY 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 FFY 2015, with a few exceptions. This post will review the elements of the S-10 2017 audit letter but to get everyone up to speed on how we got here, we will start with a brief review.
In part 2 of our FY 2020 IPPS Proposed Rule Review series, we will take a look at the one DSH item included in the proposed rule that may be of some interest to you. It appears this item stems from the fact that there are a large number of PRRB appeals involving Medicaid eligible days and the agency is struggling for ways to deal with that issue. It appears that the agency recognizes that there is a legitimate issue to be addressed in terms of including all identified Medicaid eligible days in a hospital’s cost report, but that there might be a better way to proceed and alleviate the backlog of appeals on this issue at the Provider Reimbursement Review Board.
The 2020 IPPS Proposed Rule was published in the Federal Register back in May and public comments were accepted up until June 24. We anticipate that the FY 2020 IPPS Final Rule will be published in early August (perhaps as early as this week) and any changes will go into effect October 1, 2019. In advance of the Final Rule, we thought it would be helpful to review the Medicare DSH/Uncompensated Care payment portions (pages 19406-19423 in the Federal Register) of the proposed rule as it will affect qualifying DSH hospitals.
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.
The next 340B quarterly registration period is once again upon us. The 340B registration window began on July 1st and will conclude on July 15th. Eligible entities must register in the 340B Office of Pharmacy Affairs Information System (OPAIS). More information can be found on the Office of Pharmacy Affairs (OPA) website.
The 2020 IPPS Proposed Rule was put on display for public inspection on April 23, 2019, and subsequently published in the Federal Register May 3, 2019. You can view the rule in its entirety here. If finalized, the proposed 2020 IPPS rule will affect discharges on or after October 1, 2019. Each year, CMS publishes updates to the regulations for inflation factors, wage adjustments, etc. The rates that are reviewed in this post are the non-wage index adjusted rates for specific Core-Based Statistical Areas (CBSAs) as well as other updates made to the standardized rates.
The FY 2020 Hospice Proposed Rule was put on display for public inspection on April 19, 2019. The proposed rule is scheduled to be published in the Federal Register on April 25, 2019. In the meantime, the pre-publication version can be viewed here. If finalized, this Hospice proposed rule will be effective October 1, 2019.
Each year, CMS publishes updates to the regulations for inflation factors, wage adjustments, etc. For FY 2020, CMS has proposed the following updates to the Medicare Hospice payment rates:
The FY 2020 Inpatient Skilled Nursing Facility Proposed Rule was put on display for public inspection on April 19, 2019. The proposed rule is scheduled to be published in the Federal Register April 25, 2019, however, the pre-publication can be viewed here. If finalized, this SNF rule will affect discharges on or after October 1, 2019.