The 2019 IPPS Proposed Rule will be published in the Federal Register on May 7, 2018. If finalized, these changes will go into effect October 1, 2018. The pre-published version can be viewed HERE. Public comments will be accepted until 5 p.m. EDT on June 25, 2018. Below is SCA’s "as brief as we could make it", yet comprehensive summary on the Medicare DSH/Uncompensated Care payment portion (pages 818-877) of the proposed rule as it will affect qualifying DSH hospitals.
The 2018 IPPS Final Rule was published in the Federal Register on August 14, 2017. The finalized changes will go into effect October 1, 2017. The Federal Register version can be viewed HERE (Medicare DSH begins on page 38189). Below is SCA’s brief, yet comprehensive summary on the Medicare DSH/Uncompensated Care payment portion of the final rule as it will affect DSH hospitals.
The 2018 IPPS Proposed Rule was published in the Federal Register on April 28, 2017. If finalized, these changes will go into effect October 1, 2017. The published version can be viewed HERE. Public comments will be accepted until 5 p.m. EDT on June 13, 2017. Below is SCA’s brief, yet comprehensive summary on the Medicare DSH/Uncompensated Care payment portion of the proposed rule as it will affect DSH hospitals.
Today, Health Resources and Services Administration (HRSA) released the long-awaited 340B Program Omnibus Guidelines (Mega-Guidance) for public viewing on the Federal Register website. According to the site, the Mega-Guidance will officially be published on Friday, August 28, 2015 and public comments should be submitted on or before TUESDAY, OCTOBER 27, 2015 (60 days after the Federal Register publication date). The pre-publication document can be found at:
Thursday November 20, 2014, I testified before the Provider Reimbursement Review Board (PRRB) in a jurisdictional hearing concerning the May 2014 issuance of PRRB Alert 10 that resulted from an adverse decision in the Danbury case. Much has been written about PRRB jurisdiction, and specifically, the Danbury decision and subsequent PRRB Alert 10 – including pieces authored by Southwest Consulting Associates. However, this was the first hearing that I am aware of since the issuance of Alert 10 to delve deeply into specifics of what that alert requires. If there was any question in your mind regarding the shift in the “jurisdictional” ground beneath providers’ feet, I am here to confirm for you that the ground is in fact shifting and the dominos are now falling.
On May 23, 2014, the Provider Reimbursement Review Board (PRRB) issued Alert 10 following its decision in Danbury Hospital v. Blue Cross Blue Shield Association (Danbury). This decision, and subsequent Alert, further signals a continuing trend relating to the documentation of Medicaid paid/eligible days and the importance of claiming all such “allowable costs” (or eligible patient days in the Medicare DSH context) in the initial cost report filing.
Alert 10, in conjunction with changes made to 405.1811(a)(1) and 405.1885(a)(1) in 2008 and the Agency’s interpretation of the United States Supreme Court decision in Bethesda Hospital Association v. Bowen, highlights the PRRB’s view regarding the requirement that hospitals must claim all allowable costs in its initial cost report filing and must show that any costs claimed through an appeal for Medicaid paid/eligible days could not have been claimed in the initial cost report filing. Let’s dig into this in more detail and review the actual Alert 10 requirements and why this is an issue that REQUIRES YOUR ATTENTION.
For the last few weeks, we have been focusing on the Medicare DSH payment and how the payment calculation changed due to ACA. Medicare DSH is, and always has been, a process that involves much more than the payment amount found on the cost report for WHAT the hospital should be paid. Now, there are new external factors beyond the calculation that may affect IF the hospital gets paid. The Medicare DSH game is changing and a clear message is being sent that Medicare Disproportionate Share as we know it has changed.
This is evident with the:
2015 IPPS proposed rule language covering the substantive requirement to claim costs
Issuance of the PRRB’s Alert 10
Trends in recent PRRB jurisdictional decisions