In our realm of Medicare provider reimbursement, Worksheet S-10 has been the hot topic of late. It has certainly been a heavy focus for our last few webinars and blog posts and while Worksheet S-10 has captured the provider reimbursement community's attention, it is important not to lose sight of the Medicare Disproportionate Share Hospital (DSH) program. Now, the affordable care act initially changed the Medicare DSH calculation (hence the S-10 popularity), but there have been additional changes enacted in recent rounds of rule making that hospitals should be aware of when it comes to DSH. For this reason alone, we thought that it’s a perfect time to revisit the Medicare DSH calculation starting with a basic 101 and then expand on the changes in future posts.
Hospital providers from all over the country converged at this year’s Health Financial Systems User Meeting in hopes to hear updates on the latest issues affecting Medicare reimbursement. This year’s two-day meeting curated twenty-three different presentations ranging from Medicare cost report form changes to software reviews and Medicare information updates. We could write for days on all of the information we absorbed at this year’s assembly, but after reviewing our catalog of notes and identifying the recurring themes across presentations, we’ve compiled our top four takeaways we think hospital providers should be aware of to improve their reimbursement areas, their cost reports and maintain compliance with Medicare regulations.
As you will recall from the FY 2019 IPPS final rule-making cycle, CMS issued new requirements for supporting documentation that must be submitted along with the Medicare cost report. While that final rule was posted a little over a year ago, hospitals will soon be in the midst of filing the first affected cost reports. The new Medicare cost report supporting documentation is required for cost reporting periods beginning on or after October 1, 2018.
Southwest Consulting Associates was featured in the latest issue of the First Illinois Speaks HFMA chapter magazine. Beginning on page 12, Kyle Pennington briefly reviews the FY 2020 IPPS proposed rule, summarizes the inaugural audits of 2015 Medicare cost report Worksheet S-10 data and what's coming up next for hospital providers and their reimbursement teams. We’ve also included a post-article update at the end of this post.
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.
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.
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.