Southwest Consulting Associates Blog

FY19 IPPS Final Rule: Cost Report Worksheet S-10 Is Here To Stay

Posted by Kyle Pennington on Oct 12, 2018 1:32:37 PM

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:

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Topics: Medicare DSH Reimbursement, final rule, worksheet s-10, S-10, regulations

Robust Factor 3 Comments Not Enough to Sway CMS & 2018 IPPS Final Rule

Posted by Michael Newell on Sep 5, 2017 12:53:25 PM

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:

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Topics: Medicare DSH Reimbursement, DSH Reimbursement, factor 3, final rule, S-10, worksheet s-10, regulations

2018 IPPS Final Rule: "What To Do Now" Recommendations

Posted by Michael Newell on Aug 24, 2017 8:45:00 AM

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:

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Topics: Medicare DSH Reimbursement, DSH Reimbursement, S-10, worksheet s-10, final rule

2018 IPPS Final Rule: Worksheet S-10 Comes Off the Bench

Posted by Jamie Pennington on Aug 22, 2017 9:49:09 AM

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.

 

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Topics: Medicare DSH Reimbursement, uncompensated care, worksheet s-10, Compliance, DSH Reimbursement, Industry Updates, S-10, regulations, final rule

2018 IPPS Proposed Rule: Recommendations in Advance of Final Rule

Posted by Jeff Norman on Jul 31, 2017 4:10:58 PM

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.

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Topics: Medicare DSH Reimbursement, worksheet s-10, S-10, regulations, proposed rule, final rule, CMS transmittal, DSH Reimbursement

2017 IPPS Final Rule Delays Worksheet S-10 Uncompensated Care Formula

Posted by Jamie Pennington on Sep 19, 2016 1:39:39 PM

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:

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Topics: Medicare DSH Reimbursement, S-10, final rule, regulations, uncompensated care

2017 IPPS Final Rule, Medicare DSH Reimbursement & Worksheet S-10

Posted by Michael Newell on Sep 6, 2016 12:57:56 PM

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: 

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Topics: S-10, final rule, DSH Reimbursement, regulations, uncompensated care, Medicare DSH Reimbursement

2016 OPPS Final Rule - Medicare DSH & New Substantive Reimbursement Requirement

Posted by Lindsay Webb on Apr 7, 2016 10:45:10 AM

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.  

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Topics: DSH Reimbursement, Medicare DSH Reimbursement, regulations, final rule, OPPS

About This Blog

The climate of provider reimbursement is ever-changing and this blog is intended to keep you up-to-date on the latest information regarding:

  • DSH Reimbursement
  • 340B Pharmacy Drug Discount Program
  • Compliance Issues
  • Litigation Surrounding Provider Reimbursement

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