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.
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 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.
On January 23, 2015, Michael Newell, SCA’s President, authored a blog article entitled 340B meets S-10, which can be found HERE. The impetus for this article was a report published by the Alliance for Integrity and Reform of 340B (AIR340B). In this article, the authors concluded that 340B hospitals appear to provide only a minimal amount of charity care thus calling into question whether or not Congress’ intentions for the 340B program are being met. The data used to reach this conclusion was derived from the Medicare Cost Report, CMS-2552-10, S-10 – the very data that CMS currently uses as the basis to allocate the uncompensated care pool for the Medicare DSH/uncompensated care program.
The Centers for Medicare and Medicaid Services (CMS) has posted a Questions and Answers document providing clarification related to Medicare Cost Report Worksheet S-10. If you’ll recall, CMS issued Transmittal 11 in September 2017 that made a number of revisions to the instructions for reporting data on cost report Worksheet S-10.
On October 20, 2017, CMS issued another Technical Direction Letter (TDL) extending the deadline for all IPPS hospitals to submit revised or initial FFY 2014 and 2015 Worksheet S-10’s to January 2, 2018. Southwest Consulting Associates confirmed this directly with CMS' Division of Acute Care and is monitoring the CMS website for a posted notice, which CMS also stated would be available shortly. Until the official notice is posted, please contact your MAC for additional information.
Last week, September 29, 2017, CMS issued Transmittal 11 that makes a number of revisions to the instructions for reporting data on cost report Worksheet S-10. These instructions need to be incorporated into any FFY 2014 & FFY 2015 Worksheet S-10 revisions providers are working to submit by the October 31, 2017 deadline and then for any future year submissions. In particular, the changes include:
As a result of Hurricanes Harvey, Irma and Maria, CMS posted a notice on its website last month granting a 31-day extension to IPPS hospitals in Texas, Louisiana, Florida, Georgia, South Carolina, Puerto Rico and the U.S. Virgin Islands to submit FFY 2014 and FFY 2015 revised Worksheet S-10's. CMS subsequently issued a Technical Direction Letter (TDL) extending the same 31-day extension to file updated FFY 2014 and 2015 Worksheet S-10’s to October 31, 2017 for ALL IPPS providers.
Earlier this week, CMS posted a notice on its website granting a 31-day extension to IPPS hospitals in Texas, Louisiana, Florida, Georgia, South Carolina, Puerto Rico and the U.S. Virgin Islands to submit FFY 2014 and FFY 2015 Worksheet S-10's. This comes on the heels of Hurricane Harvey, Irma and Maria, the President declaring a state of emergency and the HHS Secretary declaring a public health emergency for Texas, Louisiana, Florida, Georgia, South Carolina, Puerto Rico and the U.S. Virgin Islands. Both the President and HHS Secretary's actions allow CMS to put in place programmatic waivers based on Section 1135 of the Social Security Act.