In our realm of Medicare provider reimbursement, Worksheet S-10 has been the hot topic of late. It has certainly been a heavy focus for our last few webinars and blog posts and while Worksheet S-10 has captured the provider reimbursement community's attention, it is important not to lose sight of the Medicare Disproportionate Share Hospital (DSH) program. Now, the affordable care act initially changed the Medicare DSH calculation (hence the S-10 popularity), but there have been additional changes enacted in recent rounds of rule making that hospitals should be aware of when it comes to DSH. For this reason alone, we thought that it’s a perfect time to revisit the Medicare DSH calculation starting with a basic 101 and then expand on the changes in future posts.
As you will recall from the FY 2019 IPPS final rule-making cycle, CMS issued new requirements for supporting documentation that must be submitted along with the Medicare cost report. While that final rule was posted a little over a year ago, hospitals will soon be in the midst of filing the first affected cost reports. The new Medicare cost report supporting documentation is required for cost reporting periods beginning on or after October 1, 2018.
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.
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.
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.
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:
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.
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:
The 2019 IPPS Final Rule was put on display for public inspection on August 2, 2018 and is scheduled to be published in the Federal Register on Monday, August 17, 2018. The pre-publication version can be viewed HERE (Medicare DSH begins on page 969). SCA will be reviewing and analyzing the details of the final rule and its components and we will provide more detailed conclusions soon.