The 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.
On April 8, 2019, SCA was provided multiple copies of a MAC letter informing hospitals of potentially aberrant data reported on Worksheet S-10 for federal FY 2017. While we have only seen a few letters to date, it is our understanding that this is a CMS initiative affecting many hospitals. Here is what we have been told at this point:
CMS posted the FFY 2017 SSI ratios to their website. The FFY 2017 SSI ratio file (DSH Adjustment and 2016-2017 File [ZIP, 246KB]) can be found in the Downloads section of CMS' Disproportionate Share Hospital (DSH) webpage or by following the link below:
CMS just posted the FFY 2016 SSI ratios to their website. The FFY 2016 SSI ratio file (DSH Adjustment and 2015-2016 File [ZIP, 248KB]) can be found in the Downloads section of CMS' Disproportionate Share Hospital (DSH) webpage or by following the link below:
On October 20, 2017, CMS issued another Technical Direction Letter (TDL) extending the deadline for all IPPS hospitals to submit revised or initial FFY 2014 and 2015 Worksheet S-10’s to January 2, 2018. Southwest Consulting Associates confirmed this directly with CMS' Division of Acute Care and is monitoring the CMS website for a posted notice, which CMS also stated would be available shortly. Until the official notice is posted, please contact your MAC for additional information.
Last week, September 29, 2017, CMS issued Transmittal 11 that makes a number of revisions to the instructions for reporting data on cost report Worksheet S-10. These instructions need to be incorporated into any FFY 2014 & FFY 2015 Worksheet S-10 revisions providers are working to submit by the October 31, 2017 deadline and then for any future year submissions. In particular, the changes include:
As a result of Hurricanes Harvey, Irma and Maria, CMS posted a notice on its website last month granting a 31-day extension to IPPS hospitals in Texas, Louisiana, Florida, Georgia, South Carolina, Puerto Rico and the U.S. Virgin Islands to submit FFY 2014 and FFY 2015 revised Worksheet S-10's. CMS subsequently issued a Technical Direction Letter (TDL) extending the same 31-day extension to file updated FFY 2014 and 2015 Worksheet S-10’s to October 31, 2017 for ALL IPPS providers.
Earlier this week, CMS posted a notice on its website granting a 31-day extension to IPPS hospitals in Texas, Louisiana, Florida, Georgia, South Carolina, Puerto Rico and the U.S. Virgin Islands to submit FFY 2014 and FFY 2015 Worksheet S-10's. This comes on the heels of Hurricane Harvey, Irma and Maria, the President declaring a state of emergency and the HHS Secretary declaring a public health emergency for Texas, Louisiana, Florida, Georgia, South Carolina, Puerto Rico and the U.S. Virgin Islands. Both the President and HHS Secretary's actions allow CMS to put in place programmatic waivers based on Section 1135 of the Social Security Act.
As we all now know, CMS proposed transitioning to the use of uncompensated care cost per worksheet S-10 in the IPPS 2017 rulemaking cycle. For many reasons that we have discussed in the past and that CMS reiterated in the last rulemaking cycle, that plan was not finalized. And although many people were left thinking that CMS was going to make some reforms to the definitions and reporting processes before going forward, they did leave the door open just a bit last year with regarding to moving forward with the change to S-10 in FY 2018. As we now know, they chose to squeeze through that opening and have finalized plans to begin the transition to using worksheet S-10 beginning in FY 2018. As overall justification, CMS stated:
On Thursday, July 13, 2017, CMS announced that “amended FY 2014 cost reports due to revised or initial submissions of Worksheet S-10 received by Medicare Administrative Contractors on or before September 30, 2017, will be uploaded to the Healthcare Cost Report Information System by December 2017”. In its announcement, CMS stated that “hospitals have requested CMS provide them with an additional opportunity to revise the Worksheet S-10 submitted with their FY 2014 cost reports (starting on or after October 1, 2013, and prior to October 1, 2014)”.