The Inpatient Rehab FY 2020 Proposed Rule was put on display for public inspection on April 17, 2019. The proposed rule is scheduled to be published in the Federal Register on April 24, 2019, however, the pre-publication version can be viewed here. This IRF rule will affect discharges on or after October 1, 2019.
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:
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:
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.
In January, CMS issued a MLN Matters newsletter reviewing the new electronic system for Provider Reimbursement Review Board (PRRB) Medicare cost report appeals. The electronic system, referred to as OH CDMS (Office of Hearings Case and Document Management System), is a web-based portal that allows providers to submit all necessary appeals documents electronically.
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.
Yesterday, CMS held an Open Door Call to discuss two agenda items, one of which was the posting of the FY 2020 hospital area wage index data and occupational mix public use file. As you know, according to the FY 2020 Hospital Wage Index Development Timetable, hospitals have until February 15, 2019 to submit correction requests regarding their data.
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.