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:
Southwest Consulting Associates recently participated in a segment of the THA SOLUTIONS Podcast where SCA President Michael Newell discussed the Medicare cost report Worksheet S-10 with Texas Hospital Association's Lance Lunsford. The sixteen minute conversation was part of the podcast segment titled, "Maintain Compliance to Maximize Hospital Funding" and can be heard in its entirety by selecting the play button located at the end of this post.
Hospitals nationwide have been undergoing Worksheet S-10 “reviews” for FY 2015 that in large part culminated at the end of January 2019. Since then, there has been word that additional technical direction was provided to MACs by CMS (not yet shared with hospitals) that addresses how to apply some “findings” from those reviews. Even though the current audit process has not been fully completed, there is much to learn about what has transpired so far and how that may impact future reviews or even future changes to cost reporting instructions.
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 Uncompensated Care pool reimbursement payment is viewed as a zero-sum game, with one hospital’s reimbursement gain through the program becoming another hospital’s loss. While Worksheet S-10 has been used for UC reimbursement purposes for only a short time, audits of the S-10 data to ensure its accuracy and consistency have been a high priority for hospital providers. In its 2019 final IPPS rule, CMS stated that, due to the overwhelming feedback from commenters emphasizing the importance of audits, they would begin the inaugural audits in fall 2018.
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.
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.
The 2019 IPPS Proposed Rule was put on display for public inspection on April 24, 2018 and is scheduled to be published in the Federal Register on Monday, May 7, 2018. The pre-publication version can be viewed HERE. All public comments to the proposed rule are to be received by 5 p.m. EST on Monday, June 25, 2018.
In regards to the Medicare DSH/UC payment, Worksheet S-10 will be used to calculated two-thirds of a qualifying provider's Factor 3. SCA will be reviewing and analyzing the full details of the proposed rule and its components, and we will provide our conclusions in the coming week.