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 has provided MACs with a listing of hospitals that appear to have reported aberrant data for cost reporting years in FFY 2017.
The MACs have until Friday, April 12, 2019 to notify all impacted hospitals.
Aberrant data was identified, at least in part, by performing a year over year analysis of reported S-10 data.
The letters we have seen focus on data reported on line 20, column 2 (insured charity charges).
Hospitals must notify the MAC by April 26, 2019 whether revisions to reported S-10 data are necessary.
If changes are necessary, the hospital must submit updated data, in a MAC designated template, by May 10, 2019.
If requested by a hospital on or before May 10, 2019, a one-time extension until May 24, 2019 will be granted.
The MAC letter suggests reviewing cost reporting instructions and the MLN Matters article (SE17031) to verify Worksheet S-10 amounts are properly reported. The letter also makes reference multiple times to FY 2020 uncompensated care payment calculations and that they may be impacted for failure to respond.
As a reminder, if CMS continues with the same methodology used to calculate uncompensated care payments as they did in the FY 2019 IPPS final rule, FY 2020 Factor 3 calculations would be comprised solely of Worksheet S-10 data from 2014, 2015 and 2016 cost reports. Please note that CMS also stated in its FY 2019 final IPPS rule that it is possible they could determine that the use of multiple years of Worksheet S-10 data is no longer necessary in calculating Factor 3 for FY 2020.
We anticipate that the FY 2020 IPPS rule will be posted sometime this month so at this point, it appears we are in a wait and see situation for how CMS will use Worksheet S-10 data going forward. One thing seems to be for certain though, S-10 programs should be top-of-mind for qualifying hospitals.
Should you receive one of these MAC letters, have questions regarding the data submitted, or need help in any way, please don’t hesitate to contact us.
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