On Friday, December 1, 2017, CMS released Transmittal 1981, which clarifies the deadlines for uploading revised or initial submissions of FY 2014 and FY 2015 cost report Worksheet S-10. For revisions to be considered, CMS extended the deadline to Tuesday, January 2, 2018, for all IPPS hospitals to submit the data to their Medicare Administrative Contractor (MAC). On December 4, 2017, the provider education article, MM10378, was released related to this instruction.
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.
On Thursday, July 13, 2017, CMS announced that “amended FY 2014 cost reports due to revised or initial submissions of Worksheet S-10 received by Medicare Administrative Contractors on or before September 30, 2017, will be uploaded to the Healthcare Cost Report Information System by December 2017”. In its announcement, CMS stated that “hospitals have requested CMS provide them with an additional opportunity to revise the Worksheet S-10 submitted with their FY 2014 cost reports (starting on or after October 1, 2013, and prior to October 1, 2014)”.
On Friday, June 30, 2017, CMS released Transmittal 1863 (beginning on page 2), which included, among other items, guidance for MACs to follow for accepting cost reports containing revised Worksheet S-10 information. Similar to last year's Transmittal 1681, in order for MACs to accept amended cost reports due to revisions to Worksheet S-10 for FY 2015, CMS has put providers on notice by stating that “hospitals must submit their amended cost report containing the revised Worksheet S-10…no later than September 30, 2017.” CMS added, “Submissions received on or after October 1, 2017 will not be accepted.”