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

2019 IPPS Proposed Rule: Cost Report Worksheet S-10 to determine Two-Thirds of Factor 3 for Uncompensated Care Payment

Posted by Jamie Pennington on Apr 25, 2018 3:59:40 PM

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.

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Topics: Medicare DSH Reimbursement, uncompensated care, worksheet s-10, proposed rule, Compliance, DSH Reimbursement, Industry Updates, S-10, healthcare finance, 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: 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

IPPS Proposed Rule 2018: Factor 3 - CMS Digging Heels In

Posted by Michael Newell on Jun 22, 2017 1:10:34 PM

On April 28, 2017, CMS published the FFY 2018 IPPS Proposed Rule in the Federal Register.  Go HERE for our summary of the Medicare DSH/Uncompensated care payment portion of the rule.  After years of discussion to use Worksheet S-10 uncompensated care data to distribute the Medicare DSH/UC pool always ending with CMS “kicking the can down the road”, it appears that CMS has finally dug their heels in.  Who else just had a moment of deja vu?  

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Topics: Medicare DSH Reimbursement, DSH Reimbursement, worksheet s-10, S-10, regulations, proposed rule, uncompensated care, factor 3

2018 IPPS Proposed Rule: Factor 3

Posted by Jeff Norman on Jun 20, 2017 3:07:15 PM

On April 28, 2017, CMS published the FFY 2018 IPPS Proposed Rule in the Federal Register.  Go HERE for our summary of the Medicare DSH/Uncompensated care payment portion of the proposed rule.  After years of discussion on Worksheet S-10 and false starts on the use of uncompensated care data for Medicare DSH/UC pool distribution purposes, CMS appears to finally be moving forward with implementation.  Did anyone else have a moment of deja vu?  

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Topics: Medicare DSH Reimbursement, DSH Reimbursement, worksheet s-10, S-10, uncompensated care, proposed rule, regulations, factor 3

2018 IPPS Proposed Rule Comment Letter Submitted to CMS

Posted by Jamie Pennington on Jun 15, 2017 11:39:13 AM

The FY 2018 IPPS proposed rule was published in the Federal Register on April 28, 2017. All comments to the rule were to be submitted to CMS by Tuesday, June 13, 2017. Like in past years, Southwest Consulting Associates (SCA) performed extensive analysis of the proposed rule and submitted comments in response to CMS’ FY 2018 IPPS Notice of Proposed Rulemaking (NPRM). SCA’s comments primarily related to the proposed changes in the payment adjustment for Medicare Disproportionate Share Hospitals (DSH) including the Uncompensated Care (UC) payment component.

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

What is the 2018 IPPS Proposed Rule Factor 2?

Posted by Jeff Norman on Jun 7, 2017 12:57:16 PM

On April 28, 2017, CMS published the FFY 2018 IPPS Proposed Rule in the Federal Register.  After years of discussion on Worksheet S-10 and false starts on the use of uncompensated care data for Medicare DSH/UC pool distribution purposes, CMS appears to have finally moved forward with implementation.  Go HERE for our summary of the Medicare DSH/Uncompensated care payment portion of the proposed rule.  In this post, we will take a dive into Factor 2 as described in the proposed rule.  For a quick refresher on Factor 2, go HERE.

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Topics: Medicare DSH Reimbursement, proposed rule, DSH Reimbursement, factor 2, uncompensated care, S-10, worksheet s-10, regulations

2018 IPPS Proposed Rule: Factor 1

Posted by Jeff Norman on May 30, 2017 9:30:00 AM

On April 28, 2017, CMS published the FFY 2018 IPPS Proposed Rule in the Federal Register.  After years of discussion on Worksheet S-10 and false starts on the use of uncompensated care data for Medicare DSH/UC pool distribution purposes, CMS appears to have finally moved forward with implementation.  Go HERE for our high-level summary of the Medicare DSH/Uncompensated care payment portion of the proposed rule.  In this post, we will take a dive into Factor 1 as described in the proposed rule.  For a quick refresher on Factor 1, go HERE.

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Topics: Medicare DSH Reimbursement, DSH Reimbursement, uncompensated care, S-10, worksheet s-10, regulations, proposed rule

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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