Last Fall, CMS made updates to the cost reporting software and the rules for filing a hospital Medicare cost report. Additionally, there were new and noteworthy changes included in the FY 2019 IPPS Final Rule. Specifically, the FY 2019 Final IPPS rule included new requirements for cost reports submissions with periods beginning on or after 10/1/2018. Providers must now submit both Worksheet S-10 and Medicare DSH patient level detail along with their cost report submissions.
Southwest Consulting Associates was featured in the latest issue of the Dallas-Fort Worth Hospital Council's Interlocutor magazine. Beginning on page 24, Kyle Pennington reviews the FY 2019 IPPS rule, the inaugural audits of Medicare cost report Worksheet S-10 data and what's coming up next for hospital providers and their reimbursement teams.
The Fall 2018 issue of HFMA New Jersey's Garden State FOCUS magazine included an article titled, "FY 2019 IPPS Final Rule Update: Worksheet S-10 Is Here To Stay" which takes a look at:
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:
Now that the FY 2018 IPPS final rule has been published, we think that you need to do some things that are both in the here and now AND in the future. Here are some of the top priorities that we are managing for our clients:
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 FY 2018 IPPS proposed rule was published April 28, 2017. Public comments have been submitted and we are awaiting the final rule. For reference, the 2017 IPPS final rule was posted the first week in August 2016 so we are on the cusp on the 2018 final rule.
In our last proposed rule post, while we stated that there was a brief moment of deja vu with regards to using Worksheet S-10 to distribute the uncompensated care payment to qualifying Medicare DSH hospitals for FY 2018, we also stated that based on the language used in the proposed rule, we believe that the change will stick this time. Despite challenges on the accuracy of Worksheet S-10 data, CMS goes out of their way to lay out the reasoning for using S-10 now. And, with the issuance of Transmittal 1863 and the notice about FY 2014 S-10 revisions, our case may be even stronger now. From experience, we all know that anything can happen but we think Medicare DSH hospitals should take notice (and quickly) with this proposed rule, subsequent Transmittal and Notice and prepare themselves as best they can to deal with this significant change. Here’s what we recommend hospital’s be working on in advance of the final rule, in order of priority.
The 2017 IPPS Final Rule was posted on August 2, 2016 and will be effective October 1, 2016. Below is SCA’s summary on the rule as it affects disproportionate share hospitals (DSH).
Quick Review of the DSH Payment Under ACA
As a result of the ACA, the amount of total DSH reimbursement a provider may receive for discharges beginning October 1, 2013, is now based upon two components:
On August 2, 2016, CMS posted the 2017 IPPS final rule. While we will provide a comprehensive summary of the rule in the near future, this post relates to the changes that CMS is making regarding Medicare DSH reimbursement and the use of cost report worksheet S-10 to calculate factor 3 for federal fiscal years 2018-2021. As you recall, in the 2017 proposed rule, CMS indicated that it would begin using S-10 to calculate factor 3, at least in part, beginning in FFY 2018. However, in the final rule CMS states:
As we conclude the end of the first quarter subject to the 2016 OPPS Final Rule, hospitals MUST evaluate the new substantive reimbursement requirement (beginning on page 255 of the Federal Register 2016 OPPS Final Rule) recently imposed by CMS. Introduced in the 2015 IPPS Proposed Rule, and later adopted in the 2016 OPPS Final Rule, CMS incorporated into the regulations a concept initially introduced by the PRRB Board Rules in 2008.